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High Court of Bombay at Goa Examines Appeal Against BFAR Ruling on DDT Rate Under India-UK DTAA. Appellant Seeks Restriction of Dividend Distribution Tax to 10% Tax Treaty Rate on Dividends Paid to UK Parent Company.

The appellant, M/s. Colorcon Asia Pvt. Ltd., an Indian company and wholly owned subsidiary of Colorcon Limited, United Kingdom, filed an appeal under ...

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KAHC010028192013_1

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Madras High Court Allows Assessee's Appeal in TDS Dispute on Internet Charges Paid to Non-Resident — Payments for Telecom Connectivity Not Royalty or Fees for Technical Services. Section 40(a)(i) Disallowance Set Aside as Payments Were Not Chargeable to Tax Under the Income Tax Act, 1961.

The appellant, M/s. Cognizant Technology Solutions India Private Limited, is engaged in the development and export of computer software. For the asses...

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Supreme Court Disposes of Appeals by Authority for Advance Rulings Against High Court Judgment Quashing AAR's Rejection of Treaty Benefits. Questions Raised on Taxation of Capital Gains Under India-Mauritius DTAA and Scope of Section 245R(2) Proviso (iii) of Income Tax Act, 1961.

The disputes arose from applications for advance ruling filed by three Mauritius-incorporated companies—Tiger Global International II Holdings, Tige...

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Supreme Court Dismisses Revenue’s Appeal, Holding Compensation for Partial Termination of Agency is Capital Receipt. Termination of Agency for Territory Outside Hyderabad State Results in Sterilisation of Capital Asset, Not Taxable as Business Income Under Indian Income-tax Act, 1922.

The dispute arose from the income tax assessment of Messrs. Vazir Sultan & Sons, a registered firm, for the assessment year 1951-52. The firm was appo...

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High Court of Karnataka Hears Revenue's Appeals Against ITAT Decision Favoring Assessee on Deduction of Distributable Surplus Payment to Brand Owner. Court Examines Whether Payment is Allowable Under Section 37 of Income Tax Act, 1961 or Constitutes Application of Income or Diversion by Overriding Title.

The present set of five tax appeals arises under Section 260-A of the Income Tax Act, 1961, filed by the Revenue against the common order of the Incom...

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Bombay High Court Quashes Reassessment Notices for Non-Resident Taxpayer Due to Lack of Jurisdictional Satisfaction. Section 148 notices under Income Tax Act, 1961 set aside as Assessing Officer failed to record reasons and obtain sanction before issuing notices beyond four years.

The petitioner, a non-resident Indian residing in Dubai, was regularly assessed to tax in India on income accruing or arising in India. He had investe...