WebNov 17, 2024 · G Siempelkamp GmbH Company, 29 F.3d 1095 (6th Cir. 1994), this Court concluded that a manager had apparent authority to bind GE to a contract with a German manufacturer. In that case, GE made an offer in a purchase order to Siempelkamp, a German manufacturer, to buy an industrial laminate press. Siempelkamp then submitted … WebApr 29, 2024 · The Court of Appeal decided the IGE USA Investments Limited v HMRC case on a key point, that if there is a common law time limit for a similar remedy then the same limit should apply in equity. GE argued its case based on Molloy v Mutual Reserve Life Insurance Company from 1906, which set such a limit.
Supreme Court clarifies Samsung WHT decision in GE …
WebMay 27, 2011 · GE India Technology Centre P. Ltd. vs. Commissioner of Income-tax and Another, 327 ITR 456 has held that such payme...foreign agents. The Revenue has also relied on the judgment of the Honble Supreme Court in the case of Transmission Corporation of A.P. Ltd. vs.... CIT, 239 ITR 587. WebGE India Technology Cen. P. Ltd. v. CIT [2010] 327 ITR 456/193 Taxman 234/234 CTR 153/44 DTR 201/10 SCC 29/7 taxmann.com 18 (SC) S. 195 : Deduction of tax at source – Payment to non-resident – Obligation to deduct tax arises only when a remittance is chargeable to tax under the Act – No obligation to deduct tax arises the moment a ... richard rodgers some enchanted evening
Top direct tax cases and transfer pricing disputes in Q1 2024
WebLimited v GE Power Conversion India Private Limited (Civil Appeal No. 1647 of 2024) has held that two companies incorporated in India can validly designate a foreign seat for arbitration of their disputes. Previously, there had been inconsistent judicial precedent in this area, and lingering concerns that an offshore arbitration WebNov 17, 2024 · ...-resident is taxable in India as per case law GE India Technology Centre P. Ltd vs CIT 327 ITR 456(SC). Therefore, the Revenue is in appeal. I.T.A.No...permanent establishment in India and all their services were claimed as rendered outside India. The Assessing Officer in assessment order dated 8.12.2011 invoked section 40(a)(i) and … WebMar 6, 2024 · Thus, assessee carried out business through PE in India and GE India constituted DAPE in India for all overseas GE Group entities. Court had upheld ITAT’s view on attributing 10% of the value of supplies made to clients in India as profit arising from such supplies and attributing 26% of such profits to taxpayer’s PE in India considering ... red maple realtors