ACIT (IT) -4(1)(1), MUMBAI vs. RELIANCE JIO INFOCOMM LTD., MUMBAI

PDF · subscribers
ITA 5780/MUM/2018Status: DisposedITAT Mumbai20 January 2020AY 2018-192 pages

In favour of the Revenue: the Revenue's appeal was allowed. From the AI summary of this appeal.

AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the original order contained inadvertent typographical errors. These errors have been corrected to accurately reflect the intended meaning and factual position as per the corrigendum.

What were the facts?

This judgment is a corrigendum to a previous order passed by the ITAT Mumbai. It rectifies several typographical errors concerning the parties, amounts, fiscal domicile of an entity, and specific sections of the Income Tax Act. The corrections are made to ensure accuracy in the original order.

What were the issues?

The primary issue was the presence of typographical errors in a previously passed ITAT order. The corrigendum addresses these errors to ensure the order is factually and legally correct.

Which sections of the Income-tax Act were involved?

Section 254(1),Section 9(1)(vi),Section 9(1)(v)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, MUMBAI“I” BENCH, MUMBAI

CORRIGENDUM Per Pramod Kumar, VP: Order u/s. 254(1) of the Income Tax Act, 1961 was passed in the instant appeal on 25.11.2019. However, it has been subsequently pointed out by the assessee that certain errors have crept in this order. There are indeed inadvertent typographical errors in the order which are being rectified as follows:

1) On page no. 1 at para 2 (in last line) of page 1 (of para 2) of the order, the word ‘assessee’ be read as “Revenue” On page no. 3 at sub-para 3 (in 1st line) of the order, the word ‘assessee’ be 2) read as “Revenue” On page 3 at sub-para 4 (in 5th line) of the order, the amount ‘US $ 15,91,520’ 3) be read as “US $ 25,86,853”. On page 3 at sub-para 4 (in 12th line) of the order, the following has been 3) mentioned: ‘It was submitted by the assessee that RJ-S, being fiscally domiciled in India, is eligible to the benefits...............’ The same should be read as :

Assessment Year: 2018-19 ACIT vs. Reliance Jio Infocomm Ltd. Page 2 of 3

“It was submitted by the assessee that RJ-S, being fiscally domiciled in Singapore, is eligible to the benefits...............” On page 4 (at 31st line) of the order, the word ‘KJIPL’ be read as “RJIPL” 4) On page 10 at sub-para 10 (in 2nd, 3rd and 16h line) of the order, ‘section 5) 9(1)(vii)’ be read as “section 9(1)(vi)” 6) On page 12 at sub-para 13 (last line) of the order, ‘[i.e. Section 9(1)(v)’ be read as “[i.e. Section 9(1)(vi)]”

2.

This corrigendum forms part and parcel of, and is to be read along with the order dated 25.11.2019 supra.

More judgments on Section 9(1)(vi)

All 1,705 judgments and leading authorities on Section 9(1)(vi) →

Recent GST High Court judgments

Search GST case law →