ASSTT. COMMISSIONER OF INCOME TAX, AAYAKAR BHAWAN vs. BJ SERVICES ME COMPANY LIMITED, MAHARASHTRA

ITA 52/DDN/2024Status: DisposedITAT Dehradun19 November 2025AY 2016-17Bench: YOGESH KUMAR U.S., JUDICIAL MEMBER AND SHRIMANISH AGARWAL (Accountant Member)1 pages
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What did the Tribunal hold?

The Tribunal held that the income of a foreign company, under Section 244A of the Act, arising from the specified transactions should be taxed at the maximum marginal rate.

What were the facts?

The appeals were filed against the Revenue For Assessment Year 2015-16 and 2016-17 concerning the orders of Commissioner of Income Tax (Appeals). The core issue revolved around the taxability of income earned by a foreign company.

What were the issues?

Whether income earned by a foreign company, under Section 244A of the Income Tax Act, should be taxed at the maximum marginal rate or not.

Which sections of the Income-tax Act were involved?

Section 244A

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Cases cited in this judgment(3)Show list

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Income Tax Appellate Tribunal, DELHI

Before: YOGESH KUMAR U.S. & SHRIMANISH AGARWAL

For Appellant: CA & Sh. Vishal Mishra
Hearing: 14/11/2025Pronounced: 19/11/2025

PER YOGESH KUMAR, U.S. JM: The captioned appeals are filed by the Revenue For Assessment

Year 2015-16 and 2016-17 against the orders of Commissioner of Income

Tax (Appeals)-, Noida-2 [‘Ld. CIT(A)’ for short] dated 31/10/2023 and the appeal filed by the Assessee for Assessment Year 2017-18 challenging

the order dated 23/05/2025 passed b

The order continues below.

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