Search Results for "TDS under Section 195"

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Search Results for "TDS under Section 195"

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Supreme Court

Supreme Court Hears Appeals on Permanent Establishment of Formula One World Championship Limited; Revenue Accepts That No Royalty Was Payable Under Race Promotion Contract. High Court Had Reversed AAR and Held That FOWC Had a Permanent Establishment in India Under Article 5 of the India-UK Double Taxation Avoidance Agreement.

1 Aug 2026

The appeals arose from a tax dispute concerning the Formula One Grand Prix event in India. Formula One World Championship Limited (FOWC), a UK tax res...

High Court

Madras High Court Allows Assessee in Tax Appeal on TDS Obligation for IPLC Payments — Payment for International Private Leased Circuits Not Royalty Under Section 9(1)(vi) of Income Tax Act, 1961, and No Tax Deduction at Source Required Under Section 195

30 Apr 2026

The appeal before the High Court of Judicature at Madras arose from an order of the Income Tax Appellate Tribunal, Chennai, confirming the revision un...

High Court

Madras High Court Dismisses Revenue's Appeals in Insurance Company Tax Case — Upholds ITAT Order on Disallowance of Claims and Deductions. The court held that the assessee's method of accounting for outstanding claims and the deduction under Section 80M were correctly allowed by the Tribunal.

9 Jan 2025

The case involves a batch of appeals filed by the Principal Commissioner of Income Tax, Chennai, under Section 260A of the Income Tax Act, 1961, again...

High Court

Bombay High Court Dismisses Petitioner's Challenge to TDS Demand in Trademark Acquisition Case Due to Alternate Remedy. Court holds that the writ petition under Article 226 is not maintainable when an efficacious remedy of appeal under Section 253 of the Income-tax Act, 1961 is available, without adjudicating on the merits of the territoriality principle or limitation.

23 Sep 2024

The petitioner, Hindustan Unilever Ltd., filed a writ petition under Article 226 of the Constitution of India challenging an order dated 23 August 202...

High Court

Bombay High Court Quashes Section 201 Notice Against Petitioner in Income Tax TDS Case — No Payment Made to Non-Resident, No Obligation to Deduct Tax Under Section 195 of the Income Tax Act, 1961. The court held that the Income Tax Officer lacked jurisdiction to treat the petitioner as an assessee in default for non-deduction of tax on share purchase where no sum was paid or credited.

26 Feb 2022

The petitioner, Ingram Micro Inc., a company incorporated in the USA, challenged the jurisdiction of the Income Tax Officer (International Taxation) t...

High Court

High Court of Bombay at Goa Allows Tax Appeals in Income Tax Reassessment Case — Limitation for Reopening Assessment Under Section 147/148 of Income Tax Act, 1961. Reassessment Notices Quashed as Issued Beyond Four-Year Limitation Period Without Establishing Failure to Disclose Material Facts.

7 Dec 2020

The case involves five tax appeals filed by M/s. Zephyr Biomedicals and M/s. Orchid Biomedical Systems against the Joint Commissioner of Income Tax, c...

Supreme Court

Supreme Court Upholds Tax Deduction at Source on Guarantee Money Paid to Non-Resident Cricket Boards for Matches Played in India. Income from matches held in India is deemed to accrue in India under Section 9(1)(i) of the Income Tax Act, 1961, attracting TDS under Section 194E.

29 Apr 2020

The case concerns an appeal by PILCOM (PAK-INDO-LANKA JOINT MANAGEMENT COMMITTEE), a committee formed by the cricket boards of Pakistan, India, and Sr...

High Court

Karnataka High Court Allows Revenue's Appeal in ITC Hotels TDS Case — Remittances to US Company for Marketing Services Held Subject to TDS Under Section 195 of Income Tax Act, 1961. The court held that the assessee was liable to deduct tax at source on payments to a non-resident for services rendered outside India, as the income was deemed to accrue or arise in India under Section 9(1)(i), and the principle of consistency did not bar the Revenue from taking a different view.

15 Jun 2015

The case involves appeals by the Commissioner of Income Tax and the Income Tax Officer (TDS) against the order of the Income Tax Appellate Tribunal (I...

High Court

Bombay High Court Quashes Reopening Notice Under Section 148 of Income Tax Act for Lack of Fresh Material. Reimbursement of Expenses Disclosed in Return and Application Under Section 195(2) Sought, No Failure to Disclose Material Facts.

24 Jan 2012

The petitioner, Monitor India Pvt. Ltd., a subsidiary of a Dutch company, challenged a notice dated 22 March 2011 issued under Section 148 of the Inco...

High Court

Bombay High Court Allows Writ Petition Against Rejection of Nil Withholding Certificate Under Section 195(3) of Income Tax Act — Past Tax Demands Not Valid Ground for Refusal. The court held that past tax demands for earlier assessment years cannot be a valid reason to reject an application under Section 195(3) for a subsequent year, as the provision is meant to determine the appropriate proportion of tax to be deducted at source on current payments.

13 Apr 2010

The petitioner, Mckinsey & Company Inc., a non-resident company incorporated in the USA with branches in India, filed an application under Section 195...

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