DY. COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION) – 3(1)(1), MUMBAI, MUMBAI vs. JEFFERIES SINGAPORE LIMITED , SINGAPORE
IN THE INCOME TAX APPELLATE TRIBUNAL, ‘I’ BENCH
MUMBAI
BEFORE: SHRI AMIT SHUKLA, JUDICIAL MEMBER
&
SHRI AMARJIT SINGH, ACCOUNTANT MEMBER
&
Dy.
Commissioner of Income
Tax
(International
Taxation)-3(1)(1)
Mumbai
Vs. M/s. Jefferies Singapore
Limited
15-20, UOB Plaza, 80
Rafeles Place
Singapore
PAN/GIR No.AADCJ0078P
(Appellant)
..
(Respondent)
Assessee by Shri Hiten Thakkar
Revenue by Shri Krishna Kumar
Date of Hearing
02/01/2025
Date of Pronouncement
02/01/2025
आदेश / O R D E R
PER BENCH:
The aforesaid appeals have been filed by the Revenue for the quantum of assessment passed u/s.143(3) / 144C for the A.Y.2016-17 and 2018-19 against final assessment order dated 31/01/2020 and 20/03/2024 respectively.
At the outset, it has been pointed out that the dispute raised in the Revenue’s appeal in A.Y.2016-17 is only with ITA No.3042 & 3043/Mum/2024 M/s. Jefferies Singapore Limited
2
regard to Rs. 4,53,339/- and since the issue pertains to FTS where the rate of tax under the DTAA is 10%, therefore, the tax effect is only Rs.45,334/-. Similarly, in A.Y.2018-19 the disputed amount in the appeal filed by the Revenue is Rs.11,58,353/- and the tax effect is Rs.1,15,836/-
.
Both the parties have agreed that the tax effect on the disputed issue is less than Rs.60,00,000/- which is a monetary limit prescribed by the CBDT vide Circular No.09/2024 dated 17/09/2024 for filing of the appeal, wherein the limit prescribed for filing of appeal by the department before the Tribunal has been capped at Rs.60,00,000/-. Admittedly here in this case the tax effect is less than Rs.60,00,000/- and accordingly, the appeals of the Revenue are dismissed in limine on account of low tax effect.
In the result, both the appeals of the Revenue are dismissed.
Order pronounced on 2nd January, 2025. (AMARJIT SINGH) (AMIT SHUKLA)
ACCOUNTANT MEMBER
JUDICIAL MEMBER
Mumbai; Dated 02/01/2025
KARUNA, sr.ps
ITA No.3042 & 3043/Mum/2024
M/s. Jefferies Singapore Limited
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Copy of the Order forwarded to :
BY ORDER,
(Asstt.