Court : Income Tax Appellate Tribunal ITAT Delhi
Reported in : (1988)25ITD193(Delhi)
..... of the well-known decision of the supreme court in the case of cit v. b.c. srinivasa setty [1981] 128 itr 294 that since the cost of its acquisition was nil, no capital gains tax could be levied. (the import entitlement was no doubt considered as a capital asset) : (1) cit v. t. kuppuswamy pillai ..... and machinery under this category would be linked to additional exports of a promotion nature...." similarly to neutralise the disadvantages of freight differential formation of indigenous shipping companies was encouraged and shipping corpn. of india was incorporated. railways also provided concessional tariff for carrying goods from the manufacturing centre to the port of loading. ..... the export targets agreed to by them...." in their report for the period 1-7-1960 to 30-6-1961, the central board of directors of the reserve bank of india, reported, inter alia, as below : .... the relatively poor export performance reflected the severe competition that all major exporters had to face abroad and .....
Tag this Judgment!Court : Income Tax Appellate Tribunal ITAT Delhi
Reported in : (1989)31ITD29(Delhi)
..... all expenditure incurred for the prosecution, or the provision of facilities for the prosecution, of scientific research, but do not include any expenditure incurred in the acquisition of rights in, or arising out of, scientific research.22. shri r. ganesan, referring us to the provisions of section 12 submitted that in the ..... administration and scientific problems in regard to the scientific research undertaken by the foundation. (f) to apply to government's public bodies, local authorities, corporations and companies or other persons for and to accept grants of money, land, donation, gifts, subscriptions and other assistance with a view to promoting the objects of the ..... that the said levy came into force with immediate effect for shipment of fresh orders of onions and was payable immediately after realisation of payments from banks on the opening of letters of credits. the shippers were further required to communicate the abovesaid price to their exporters clientele, who were to confirm .....
Tag this Judgment!Court : Income Tax Appellate Tribunal ITAT Delhi
Reported in : (2005)96TTJ(Delhi)1
..... the user to operate the program, for example, where the transferee is granted limited rights to reproduce the program. this would be the common situation in transactions for the acquisition of a program copy. the rights transferred in these cases are specific to the nature of computer programs. they allow the user to copy the program, for example onto ..... following features: i) the object of the contract is to install and run the gsm cellular equipment from the view point of both the parties. ii) the affiliate company is a company controlled by the assessee and, therefore, it is in effect the assessee which is involved in the operations regarding both the supply and the installation of the equipment. ..... l.o. being considered as pe of the assessee company, mr. syali submitted that the l.o did not carry on any business, as required by article 5.1 of the dtaa so that it can be considered as a pe. he pointed out that there is prohibition by the reserve bank of india on the l.o. from carrying on .....
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