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- SFDC Irelands Services Deemed Technical under Tax Law: Delhi . . .
The respondents argued that SFDC Ireland was providing comprehensive service experiences or solutions with the help of technology embedded in the software, indicating a level of customization and technical service
- IN THE HIGH COURT OF DELHI AT NEW DELHI W. P. (C) 12847 2024 . . .
petitioner to receive payments from SFDC India without any withholding tax (TDS) In its application, the petitioner referred to the decision of this court in petitioner’s own case for the prior year, AY 2024-25, rendered on 11 03 2024, captioned SFDC Ireland Limited v Commissioner of Income Tax Another1 Pursuant to the said
- Sfdc Ireland Limited vs Commissioner Of Income Tax Anr. on . . .
The obligation of SFDC Ireland as per Section 4 of the Reseller Agreement was to provide SFDC products as notified from time to time The price for those products was to be as per the stipulations contained in Exhibit A
- Delhi High Court: Services Offered by Irish Co to Indian . . .
The Delhi High Court has nullified the order denying ‘Nil’ or lower Tax Deducted at Source (TDS) certificates stating that the services provided by the assessee, an Irish company, SFDC Ireland Ltd to its Indian counterpart salesforce com India Pvt Ltd were not technical
- Delhi High Court Directs Issuance of Nil Deduction . . .
The Delhi High Court ruled in favor of SFDC Ireland, setting aside the Assessing Officer’s (AO) order that had imposed a 2% withholding tax rate under Section 197 of the Income Tax Act, 1961, on payments made by SFDC India for the Financial Year (FY) 2024-25 The court held that:
- SFDC+Ireland+Limited | Indian Case Law - CaseMine
In evaluating SFDC's factual challenge, the court "may not presume the truthfulness of the factual allegations in the complaint, but may consider evidence to resolve the disputed jurisdictional facts " SK Fin SA v La Plata Cty Bd of Cty Comm'rs, 126 F 3d 1272, 1275 (10th Cir 1997)
- SFDC IRELAND LIMITED Vs COMMISSIONER OF INCOME TAX ANR . . .
This writ petition impugns the certificate dated 16 October 2023 as also the order dated 18 October 2023 issued and passed by the second respondent in purported exercise of powers conferred by Section 197 of the Income Tax Act, 19611
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