Judgment Search Results Home > Cases Phrase: protection of women from domestic violence act 2005 chapter iii powers and duties of protection officers service providers etc Court: income tax appellate tribunal itat delhi Page 1 of about 1 results (0.165 seconds)

Additional Commissioner of Vs. Nestle India Ltd.

Court : Income Tax Appellate Tribunal ITAT Delhi

Reported in : (2005)94TTJ(Delhi)53

..... of the said royalty were fully covered by the provisions of section 40a(2)(b) and section 92 of the it act, 1961.although gross payment of 4.2 per cent on domestic sales and 6 per cent on export sales had actually been paid by the assessee, a comparison of net payment (after tds) of 3.5 per cent and 5 per cent for domestic sales and export sales, respectively, was made against overall gross limits of 5 per cent and 8 per cent laid down by the government to justify the said ..... -how and assistance from its foreign collaborator for which purpose it had entered into nine agreements.these agreements provided for the assessee to use all available know-how relating to manufacture of various products, its future improvements and development, deputing experts for matters requiring on the spot technical assistance, arrangement for training of technical persons and generally advising the assessee on all the technical matters concerning manufacturing operations, productions, methods, quality control, etc. ..... he pointed out that part b of the agreement pertained to "duties and obligation of spn", part c pertained to "duties and obligation of the assessee", part d pertained to "consideration", while part e pertained to "terms and termination" and part f "miscellaneous provisions". ..... the powers under section 92 could be applied-only if the department had evidence or material to the effect that payments made to a foreign company were not commensurate with the market value of the services received.5. .....