SFDC Ireland Limited Vs Commissioner Of Income Tax & Another
.... ith a customer, partner, or Additional Reseller for the provision of the SFDC Products, Vendor shall provision the SFDC Products as soon as reasonably practicable, subject to the contract being compliant with Vendor's policies for the provisioning of the SFDC Products as notified to Reseller fro ...
Delhi High Court
National Petroleum Construction Company Vs Deputy Commissioner Of Income Tax, Circle 2(2), International Taxation, New Delhi & Anr
.... d as payable by the Assessee and any excess tax deducted is refundable with interest. Interference is not warranted at this stage. 46. Moreover, in course of hearing, Counsel for the Revenue handed us a Draft Assessment Order, issued in respect of the Assessment Year in question, that is 202 ...
Supreme Court Of India
Cloudtail India Private Limited Vs Commissioner Of Income Tax (TDS) Delhi & Anr.
.... Direct Taxes vide Notification 8/2018 as well as the Rule 28AA of the IT Rules which lay down the procedures and parameters for issuing certificates under Section 197 of the Act. He submits that the scope of scrutiny under Section 197 read with Rule 28AA is limited and as the AO had neither ...
Delhi High Court
Camions Logistics Solutions Private Limited Vs Joint Commissioner Of Income Tax, OSD, TDS Circle-73-1, New Delhi & Anr
.... -1 (supra) that the assessing officer cannot ignore the mandate of Rule 28AA and proceed on any other basis as the Government is bound to follow the rules and standards they themselves had set on pain of their action being invalidated. The relevant portion of Rule 28AA of the Income Tax Rules re ...
Delhi High Court
Link Quest Technologies Limited Vs Commissioner Of Income Tax TDS Delhi I New Delhi & Anr
.... once again issued the TDS Certificate to the petitioner for the Financial Year 2020-21 at 1.5%. 4. He contends that the assessing officer is bound to indicate reasons for allowing or disallowing an application under Section 197 of the Act and that rejection of application under Section 197 ...
Delhi High Court
Bently Nevada LLC Vs Income Tax Officer, Ward-1(1) (2), International Taxation & Anr
.... urther note on the file. 21. Thus it will be seen that the direction given by the CIT (IT) for issuing the TDS at 5% was only for two ostensible reasons, the first being that the PE had been held to be there in India. This cannot be per se the reason for increasing the TDS from 1.5% to 5%. ...
Delhi High Court
M/s Central Advertising Agency Vs Union of India
.... films; or (vi) the rendering of any services in connection with the activities referred to in sub-clauses (i) to (iv), (iva)and (v)". 4. According to the petitioner, the provisions clearly indicates that no TDS is liable to be deducted with respect to the royalty paid to the petitioner whic ...
High Court Of Kerala
Larsen and Toubro Ltd. and Another Vs The Assistant Commissioner of Income Tax (TDS) and Others
.... ferred to in Section 197 for which the application under Sub-rule (1) of Rule 28 has been made; or (ii) at the average of the average rates of tax paid by the assessee in the last three years; whichever is higher. Rule 29B governs applications for certificates authorising receipt of interes ...
Bombay High Court
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