1.   Cable & Wireless Networks India Private Limited [Relating to section 195]

In the absence of there being any permanent establishment in India,  income is not at all taxable here.

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2.    M/S. ROLTA COMPUTER & INDUSTRIES PRIVATE LIMITED (BHC) [Relating to section 2(10) of Maharashtra Sales Tax Act] 

In context of Transfer of Right to Use under Sale Tax/VAT regime (can be used in section 9(1)(vi) Income Tax Act- International Taxation-equipment royalty, finds applied by AAR similar ratio / principle in DELL; ISRO and Cable and Wireless cases).

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3.    THE INDUSTRIAL CREDIT AND INVESTMENT CORPORATION OF INDIA LTD.(ICICI) (BHC) [Relating to section 148]

With regard to the next two assessment years i.e. 1995-96 and 1996-97 are concerned, the assessment has been re-opened within the period of 4 years from the date of the assessment orders; therefore, the benefit of exception under proviso to 147 is not available to the assessee for these two assessment years.

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4.    AUTOMATED SECURITIES CLEARANCE INC [Relating to section 80HHE] 

In the above case question of law admitted. “Whether on the facts and in the circumstances of the case and in law, deduction under section 80HHE of the Act is allowable to a company incorporated in the USA in view of Article 26(2) of India -USA DTAA?”

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