87 ITD 653 (Kol.)(TM). (c) Dy. DIT v. Preroy A.G

307 ITR 418Reported decision2008#898 most cited

What is 87 ITD 653 (Kol.)(TM). (c) Dy. DIT v. Preroy A.G authority for?

Amounts received for services rendered are not treated as Fees for Technical Services (FTS) under Article 12(4)(b) of a tax treaty if the 'make available' condition is not satisfied.

118

judgments rely on this decision, according to BharatTax’s citation analysis of 366,339 Indian tax judgments — from 2014 to 2025.

Also referred to as

Dy. DIT v. Preroy A.G · 307 ITR 418 · Article 12(4)(b) · tax treaty · FTS · make available condition · fees for technical services

Sections most often in play

Section 1961Section 143(3)Section 9(1)(vii) of the ActSection 144C(13)Section 9(1)(vii)Section 143(2)Section 143(3) of Income-tax ActSection 144C

Issues it is cited on

section 9(2)fees for included servicessection 9(1)(vii)(b)section 9(1)(vii)section 90(2)enduring benefitinterest under section 234ctax treatyfees for technical servicessection 9(1)section 9(1)(vi)section 90

Judgments citing 87 ITD 653 (Kol.)(TM). (c) Dy. DIT v. Preroy A.G

Nunhems Netherlands B.V., Napoleonsweg, Netherlands vs. Assistant Commissioner of Income Tax, International Taxation, Gurgaon

In the result, appeal of the assessee in ITA No

ITA 3382/DEL/2023[2021-22]Status: DisposedITAT Delhi08 Dec 2025AY 2021-22

Bench: Shri Vikas Awasthy & Shri Naveen Chandra

For Appellant: Shri Nageshwar Rao, AdvFor Respondent: Ms. Anjula Jain, CIT-DR
Section 143(3)Section 144C(13)Section 270Section 9(1)(vi)

…finition of Fees for Technical Service (FTS) as per article 12(5)(b) of the tax treaty and covered under section 9(1)(vii) of the IT Act-1961 and Article-12 of the tax treaty 42. The ld DR relied on the decision in the Intertek Testing Services, in (2008) (307 ITR 418), by Authority of Advance Ruling (AAR) that the expression "technical services" cannot be construed in narrow sense as also on in the case of G.V.K. Industries 371 ITR 453 (SC), wherein it Page 26 of 33 Nunhems Netherlands [A.Y 2021-22] was held by the apex court that advice given by a financial consultancy firm on the modalities of procuring lo…

Solvay S A, Mumbai vs. The Deputy Commissioner of Income Tax International Tax Circle 4(2)(2), Mumbai

In the result, the appeal is partly allowed

ITA 2071/MUM/2025[2022-23]Status: DisposedITAT Mumbai27 Oct 2025AY 2022-23

Bench: Shri Saktijit Dey & Shri Narendra Kumar Billaiya

For Respondent: Shri Vijay Mehta
Section 143(3)Section 9(1)(vii)

…it bluntly, a machine cannot be a manager." 16 ITA No. 2071/Mum/2025 (A.Y.2022-23) Solvay S. A. vs. Dy. CIT(IT) Reference can be also made to the decision of the Authority for Advance Rulings in In Re: Intertek Testing Services India Private Limited, [2008] 307 ITR 418, wherein it was elucidated:- "First, about the connotation of the term "managerial". The adjective "managerial" relates to manager or management. Manager is a person who manages an industry or business or who deals with administration or a person who organizes other people's activity [New Shorter Oxford Dictionary]. As pointed out by the Supreme…

Deputy Commissioner of Income Tax, Gurgaon vs. Hays Business Solutions Private Limited, Gurgaon

The appeal of the Revenue is dismissed

ITA 3003/DEL/2023[2014-15]Status: DisposedITAT Delhi29 May 2025AY 2014-15

Bench: SHRI MAHAVIR SINGH (Vice President), SHRI MANISH AGARWAL (Accountant Member)

Section 143(2)Section 143(3)Section 195(1)Section 250Section 37Section 40

…. (346 ITR 467) (Karnataka High Court)  Endemol India Private Limited (264 CTR 117) (AAR)  Bharti Axa General Insurance Co. Ltd., In re (326 ITR 477) (AAR Delhi)  Cummins Ltd, In re (381 ITR 44) (AAR Delhi)  Intertek Testing Services India (P) Ltd. (AAR) (307 ITR 418)  Invensys Systems Inc. vs DIT (AAR) (317 ITR 438)  Given the above, the Assessee is not required to withhold tax on payment of management fee which is not chargeable to tax in India. Reliance in this regard is placed on the decision of Hon'ble Supreme Court in case of GE India Technology Centre Private Limited vs CIT (327 ITR 456) wherein it h…

DCIT(It)-3(1)(1), Mumbai vs. Jefferies International Ltd, Mumbai

Accordingly, the grounds raised by the assessee are allowed

ITA 2342/MUM/2024[2020-21]Status: DisposedITAT Mumbai31 Dec 2024AY 2020-21

Bench: Shri Saktijit Dey, Vp & Ms. Padmavathy S, Am

For Appellant: Shri Nishant Thakkar &For Respondent: Shri Krishna Kumar

…er words, the technical knowledge or skills of the provider should be imparted to and absorbed by the receiver so that the receiver can deploy similar technology or techniques in the future without depending on the provider.” In the case of Intertek Services (307 ITR 418), the AAR has observed on the term ‘make available’ as under : "By making available the technical skills or know-how, the recipient of service will get equipped with that knowledge or expertise and be able to make use of it in future, independent of the service provider. In other words, to fit into the terminology 'make available', the technical…

DCIT(It)-3(1)(1), Mumbai vs. Jefferies International Ltd, Mumbai

Accordingly, the grounds raised by the assessee are allowed

ITA 2341/MUM/2024[2021-22]Status: DisposedITAT Mumbai31 Dec 2024AY 2021-22

Bench: Shri Saktijit Dey, Vp & Ms. Padmavathy S, Am

For Appellant: Shri Nishant Thakkar &For Respondent: Shri Krishna Kumar

…er words, the technical knowledge or skills of the provider should be imparted to and absorbed by the receiver so that the receiver can deploy similar technology or techniques in the future without depending on the provider.” In the case of Intertek Services (307 ITR 418), the AAR has observed on the term ‘make available’ as under : "By making available the technical skills or know-how, the recipient of service will get equipped with that knowledge or expertise and be able to make use of it in future, independent of the service provider. In other words, to fit into the terminology 'make available', the technical…

Deputy Commissioner of Income Tax(It)-3(1)(2), Mumbai vs. Jefferies International Ltd, Mumbai

Accordingly, the grounds raised by the assessee are allowed

ITA 1775/MUM/2024[2019-20]Status: DisposedITAT Mumbai31 Dec 2024AY 2019-20

Bench: Shri Saktijit Dey, Vp & Ms. Padmavathy S, Am

For Appellant: Shri Nishant Thakkar &For Respondent: Shri Krishna Kumar

…er words, the technical knowledge or skills of the provider should be imparted to and absorbed by the receiver so that the receiver can deploy similar technology or techniques in the future without depending on the provider.” In the case of Intertek Services (307 ITR 418), the AAR has observed on the term ‘make available’ as under : "By making available the technical skills or know-how, the recipient of service will get equipped with that knowledge or expertise and be able to make use of it in future, independent of the service provider. In other words, to fit into the terminology 'make available', the technical…

Deputy Commissioner of Income Tax(It)-3(1)(2), Mumbai vs. Jefferies International Ltd, Mumbai

Accordingly, the grounds raised by the assessee are allowed

ITA 1774/MUM/2024[2018-19]Status: DisposedITAT Mumbai31 Dec 2024AY 2018-19

Bench: Shri Saktijit Dey, Vp & Ms. Padmavathy S, Am

For Appellant: Shri Nishant Thakkar &For Respondent: Shri Krishna Kumar

…er words, the technical knowledge or skills of the provider should be imparted to and absorbed by the receiver so that the receiver can deploy similar technology or techniques in the future without depending on the provider.” In the case of Intertek Services (307 ITR 418), the AAR has observed on the term ‘make available’ as under : "By making available the technical skills or know-how, the recipient of service will get equipped with that knowledge or expertise and be able to make use of it in future, independent of the service provider. In other words, to fit into the terminology 'make available', the technical…

Pr. Commissioner of Income Tax- 2 vs. Ciena Communications India Pvt. Ltd

ITA/629/2019HC Delhi13 Nov 2024

Bench: HON'BLE MR. JUSTICE VIBHU BAKHRU,HON'BLE DR. JUSTICE SWARANA KANTA SHARMA

Section 40Section 9

…further analysis of the scope of phrase "technical services" and "Make Available" is made keeping in view the explanations offered by the assessee on these phrases in its replies. "Technical Services" It was held in Intertek Testing Services, in (2008) (307 ITR 418) by Authority of Advance Ruling (AAR) that the expression "technical services" cannot be construed in narrow sense. It has been observed therein that the term "technical" ought not to be confined only to technology relating to engineering, manufacturing or other applied sciences. Professional service imbued with expertise could be regarded…

Pi. Commissioner of Income Tax - 2 vs. Ciena Communications India Pvt Ltd

ITA/628/2019HC Delhi13 Nov 2024

Bench: HON'BLE MR. JUSTICE VIBHU BAKHRU,HON'BLE DR. JUSTICE SWARANA KANTA SHARMA

Section 40Section 9

…further analysis of the scope of phrase "technical services" and "Make Available" is made keeping in view the explanations offered by the assessee on these phrases in its replies. "Technical Services" It was held in Intertek Testing Services, in (2008) (307 ITR 418) by Authority of Advance Ruling (AAR) that the expression "technical services" cannot be construed in narrow sense. It has been observed therein that the term "technical" ought not to be confined only to technology relating to engineering, manufacturing or other applied sciences. Professional service imbued with expertise could be regarded…

M/S. Tirubala International Private Limited, Kanpur vs. Deputy Commissioner of Income Tax, Range-VI, Kanpur

In the result, the appeal of the assessee is partly allowed

ITA 147/LKW/2018[2014-15]Status: DisposedITAT Lucknow25 Oct 2024AY 2014-15

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudharya.Y. 2014-15 Tirubala International Pvt. Ltd., Deputy Commissioner Of C-7, Panki Industrial Area, Vs. Income Tax, Range-Vi, Kanpur Kanpur, U.P. Pan:Aaect2086J (Appellant) (Respondent) Assessee By: Sh. Vikas Garg, Fca Revenue By: Sh. Sanjeev Krishna Sharma, Addl Cit Dr Date Of Hearing: 02.09.2024 Date Of Pronouncement: 25.10.2024 O R D E R Per Sh. Nikhil Choudhary: This Is An Appeal Filed Against The Order Of The Ld. Cit(A), Dismissing The Appeal Of The Assessee That Was Filed Against The Order Of The Dcit-6, Kanpur Passed On 19.12.2016. The Grounds Of Appeal Are As Under:- “1. That The Ao, Has Erred In Law & On Facts In Making An Addition Of Rs. 29,164/- On Account Of Late Payment Towards Employees Contribution To Esi. 2. That The Authorities Below Have Failed To Appreciate That The Payment Of Rs.29,164 Towards Employee'S Contribution To Provident Fund Was Made Before The "Due Date" Of Filing Return Of Income U/S 139(1) Of The Income Tax Act 1961 Therefore There Could Not Be Any Addition Of The Aforesaid Amount To The Returned Income. 3. That The Authorities Below Have Failed To Appreciate That The Due Date As Mentioned In 36(1) (Va) Is To Be Read In Conjunction With Section 43B(B)

For Appellant: Sh. Vikas Garg, FCAFor Respondent: Sh. Sanjeev Krishna Sharma, Addl CIT DR
Section 139(1)Section 195Section 36(1)(va)Section 40Section 43B

…esearch Lab. In the circumstances there was no scope for disallowance under section 40(a)(i)(a).In support of his averments the Ld AR placed reliance on the decision of the Authority for Advanced Rulings in the case of Interteck Testing Servies (P) Ltd. In re 307 ITR 418 (AAR) (New Delhi), wherein, the Authority for advanced ruling held that under Article 13 of treaty with UK, payment of consideration would be regarded as 'fee for technical /included services' only if twin test of rendering services and making technical knowledge available at the same time is satisfied and that to fit into the terminology 'make a…

DCIT, Mumbai vs. Jefferies Llc, Mumbai

ITA 1026/MUM/2024[2018-19]Status: DisposedITAT Mumbai28 Jun 2024AY 2018-19
For Respondent: “i. Whether on facts and in circumstances of the case and in the law, the
Section 143(3)Section 144C(3)Section 147Section 153Section 250Section 9

…er words, the technical knowledge or skills of the provider should be imparted to and absorbed by the receiver so that the receiver can deploy similar technology or techniques in the future without depending on the provider.” In the case of Intertek Services (307 ITR 418), the AAR has observed on the term 'make available' as under : "By making available the technical skills or know-how, the recipient of service will get equipped with that knowledge or expertise and be able to make use of it in future, independent of the service provider. In other words, to fit into the terminology 'make available', the technical…

DCIT It 3.1.1, Mumbai vs. Jefferies Llc, Mumbai

ITA 1023/MUM/2024[2014]Status: DisposedITAT Mumbai28 Jun 2024
For Respondent: “i. Whether on facts and in circumstances of the case and in the law, the
Section 143(3)Section 144C(3)Section 147Section 153Section 250Section 9

…er words, the technical knowledge or skills of the provider should be imparted to and absorbed by the receiver so that the receiver can deploy similar technology or techniques in the future without depending on the provider.” In the case of Intertek Services (307 ITR 418), the AAR has observed on the term 'make available' as under : "By making available the technical skills or know-how, the recipient of service will get equipped with that knowledge or expertise and be able to make use of it in future, independent of the service provider. In other words, to fit into the terminology 'make available', the technical…

Jcdecaux S.A., New Delhi vs. ACIT, Circle-2(1)(2), International Taxation, New Delhi

In the result, the appeal of the assessee is party allowed

ITA 2473/DEL/2022[2018-19]Status: DisposedITAT Delhi03 May 2024AY 2018-19

Bench: Dr. B. R. R. Kumarms. Astha Chandra

For Appellant: Sh. K. M. Gupta, Adv. &For Respondent: Sh. Om Parkash, Sr. DR
Section 143(3)Section 234BSection 270ASection 9(1)(vii)

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘D’, NEW DELHI Before Dr. B. R. R. Kumar, Accountant Member Ms. Astha Chandra, Judicial Member ITA No. 2473/Del/2022 : Asstt. Year: 2018-19 JCDECAUX S.A, Vs ACIT, C/o. JCDecaux Advertising India P Circle 2(1)(2), Ltd., Plot No. 153, 3rd Floor, Okhla New Delhi Industrial Estate, Phase-III, New Delhi 110020 (APPELLANT) (RESPONDENT) PAN No. AACCJ 8567 A Assessee by : Sh. K. M. Gupta, Adv. & Ms. Saloni Shital, AR Revenue by : Sh. Om Parkash, Sr. DR Date of Hearing: 12.04.2024 Date of Pronouncement: 03.05.2024 ORDER Per Dr. B. R. R. Kumar, Accountant Member: The prese…

DCIT Circle-24(2), New Delhi vs. Sunbeam Auto Pvt Ltd., New Delhi

In the result, the appeal of the assessee in ITA No

ITA 673/DEL/2020[2012-13]Status: DisposedITAT Delhi27 Dec 2023AY 2012-13

Bench: Shri Shamim Yahya & Shri Challa Nagendra Prasada.Yr. : 2012-13 Sunbeam Lightweighting Vs. Dcit, Circle 24(2), Solutions Pvt. Ltd. New Delhi – 110002 (Formerly: Sunbeam Auto Pvt. Ltd), 38/6, K.M. Stone, Delhi-Jaipur Highway, Narsingpur, Gurgaon-122001 (Pan: Aafcn8583K) (Appellant) (Respondent) & Ay 2012-13 Dcit, Circle 24(2), Sunbeam Auto Pvt. Ltd, Room No. 328, Cr Building, Vs. S-323, Panchsheel Park, Ip Estate, New Delhi – 110 017 New Delhi – 2 (Pan: Aaabcs2948F) (Respondent) (Appellant) Assessee By : Ms. Sashi Kapila, Adv., Sh. Sushil Kumar, Adv. & Sh. Parvesh Kumar, Adv. Department By : Sh. Anuj Garg, Sr. Dr. Date Of Hearing : 20.12.2023 Date Of Pronouncement : 27.12.2023 Order Per Shamim Yahya, Am : The Assessee As Well As Revenue Has Filed The Cross Appeals Against The Order Of The Ld. Cit(A)-8, New Delhi Relating To Assessment Year 2012-13 On The Following Grounds:-

For Appellant: Ms. Sashi Kapila, Adv., Sh. SushilFor Respondent: Sh. Anuj Garg, Sr. DR
Section 143(3)Section 14ASection 264Section 40Section 43(1)Section 43(6)

…ll as the market. Further this would also entail transfer of technical information and knowledge between M./s ETCS and the assessee providing enduring benefits to the assessee. 6. It is vital to mention that in the case of Intertek Testing Services, in (2008) 307 ITR 418, the AAR held that the expression ‘Technical Services’ cannot be construed in a narrow sense. It has been observed that the terms ‘technical’ ought not to be confined in India only to technology relating to engineering, manufacturing or other applied sciences. In this regard, it is important to cite an important ruling by the AAR dated 17.01.2012…

Sunbeam Lightweighting Solutions Pvt Ltd (Formely Sunbeam Auto Pvt Ltd), Gurgaon vs. DCIT Circle-24(2), New Delhi

In the result, the appeal of the assessee in ITA No

ITA 115/DEL/2020[2012-13]Status: DisposedITAT Delhi27 Dec 2023AY 2012-13

Bench: Shri Shamim Yahya & Shri Challa Nagendra Prasada.Yr. : 2012-13 Sunbeam Lightweighting Vs. Dcit, Circle 24(2), Solutions Pvt. Ltd. New Delhi – 110002 (Formerly: Sunbeam Auto Pvt. Ltd), 38/6, K.M. Stone, Delhi-Jaipur Highway, Narsingpur, Gurgaon-122001 (Pan: Aafcn8583K) (Appellant) (Respondent) & Ay 2012-13 Dcit, Circle 24(2), Sunbeam Auto Pvt. Ltd, Room No. 328, Cr Building, Vs. S-323, Panchsheel Park, Ip Estate, New Delhi – 110 017 New Delhi – 2 (Pan: Aaabcs2948F) (Respondent) (Appellant) Assessee By : Ms. Sashi Kapila, Adv., Sh. Sushil Kumar, Adv. & Sh. Parvesh Kumar, Adv. Department By : Sh. Anuj Garg, Sr. Dr. Date Of Hearing : 20.12.2023 Date Of Pronouncement : 27.12.2023 Order Per Shamim Yahya, Am : The Assessee As Well As Revenue Has Filed The Cross Appeals Against The Order Of The Ld. Cit(A)-8, New Delhi Relating To Assessment Year 2012-13 On The Following Grounds:-

For Appellant: Ms. Sashi Kapila, Adv., Sh. SushilFor Respondent: Sh. Anuj Garg, Sr. DR
Section 143(3)Section 14ASection 264Section 40Section 43(1)Section 43(6)

…ll as the market. Further this would also entail transfer of technical information and knowledge between M./s ETCS and the assessee providing enduring benefits to the assessee. 6. It is vital to mention that in the case of Intertek Testing Services, in (2008) 307 ITR 418, the AAR held that the expression ‘Technical Services’ cannot be construed in a narrow sense. It has been observed that the terms ‘technical’ ought not to be confined in India only to technology relating to engineering, manufacturing or other applied sciences. In this regard, it is important to cite an important ruling by the AAR dated 17.01.2012…

Sunbeam Lightweighting Solutions Pvt Ltd (Formely Sunbeam Auto Pvt Ltd), Gurgaon vs. DCIT Circle-24(2), New Delhi

ITA 117/DEL/2020[2015-16]Status: DisposedITAT Delhi11 Oct 2023AY 2015-16

Bench: Sh. M. Balaganesh & Sh.Anubhav Sharma

Section 143(3)Section 195Section 234Section 234ASection 40Section 9Section 9(1)(vii)Section 9(2)

…ll as the market. Further this would also entail transfer of technical information and knowledge between M./s ETCS and the assessee providing enduring benefits to the assessee. 6. It is vital to mention that in the case of Intertek Testing Services, in (2008) 307 ITR 418, the AAR held that the expression ‘Technical Services’ cannot be construed in a narrow sense. It has been observed that the terms ‘technical’ ought not to be confined in India only to technology relating to engineering, manufacturing or other applied sciences. In this regard, it is important to cite an important ruling by the AAR dated 17.01.2012…

Sunbeam Lightweighting Solutions Pvt Ltd (Formely Sunbeam Auto Pvt Ltd), Gurgaon vs. DCIT Circle-24(2), New Delhi

ITA 116/DEL/2020[2014-15]Status: DisposedITAT Delhi11 Oct 2023AY 2014-15

Bench: Sh. M. Balaganesh & Sh.Anubhav Sharma

Section 143(3)Section 195Section 234Section 234ASection 40Section 9Section 9(1)(vii)Section 9(2)

…ll as the market. Further this would also entail transfer of technical information and knowledge between M./s ETCS and the assessee providing enduring benefits to the assessee. 6. It is vital to mention that in the case of Intertek Testing Services, in (2008) 307 ITR 418, the AAR held that the expression ‘Technical Services’ cannot be construed in a narrow sense. It has been observed that the terms ‘technical’ ought not to be confined in India only to technology relating to engineering, manufacturing or other applied sciences. In this regard, it is important to cite an important ruling by the AAR dated 17.01.2012…

Aluminium Pechiney, New Delhi vs. DCIT, Circle-1(1)(1) Int. Tax., New Dehi

In the result, appeal is dismissed

ITA 9484/DEL/2019[2011-12]Status: DisposedITAT Delhi06 Sept 2023AY 2011-12

Bench: Shri G.S. Pannu, Hon’Ble & Shri Saktijit Dey, Hon’Ble Vice-Assessment Year: 2010-11 With Assessment Year: 2011-12 With Assessment Year: 2010-11 Aluminium Pechiney, Vs. Dcit, C/O- Ca, Praveen Gambhir, Circle-1(1)(1), 87-B, Masjid Moth Ph-2, International Taxation, Dda Flats, G.K. 3, New Delhi New Delhi Pan :Aaica3338C (Appellant) (Respondent)

Section 143(3)Section 154

…IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI BENCH: ‘D’ NEW DELHI BEFORE SHRI G.S. PANNU, HON’BLE PRESIDENT AND SHRI SAKTIJIT DEY, HON’BLE VICE-PRESIDENT Assessment Year: 2010-11 With Assessment Year: 2011-12 With Assessment Year: 2010-11 Aluminium Pechiney, Vs. DCIT, C/o- CA, Praveen Gambhir, Circle-1(1)(1), 87-B, Masjid Moth Ph-2, International Taxation, DDA Flats, G.K. 3, New Delhi New Delhi PAN :AAICA3338C (Appellant) (Respondent) Assessee by Sh. Praveen Gambhir, CA Department by Sh. Sanjay Kumar, Sr. DR Sh. Mrinal Kr. Das, Sr. DR Date of hearing 09.06.2023 Date of pronouncement 06.09.2023 ORDER Captioned a…

Aluminium Pechiney, New Delhi vs. DCIT, Circle-1(1)(1) Int. Tax., New Dehi

In the result, appeal is dismissed

ITA 9483/DEL/2019[ 2010-11]Status: DisposedITAT Delhi06 Sept 2023

Bench: Shri G.S. Pannu, Hon’Ble & Shri Saktijit Dey, Hon’Ble Vice-Assessment Year: 2010-11 With Assessment Year: 2011-12 With Assessment Year: 2010-11 Aluminium Pechiney, Vs. Dcit, C/O- Ca, Praveen Gambhir, Circle-1(1)(1), 87-B, Masjid Moth Ph-2, International Taxation, Dda Flats, G.K. 3, New Delhi New Delhi Pan :Aaica3338C (Appellant) (Respondent)

Section 143(3)Section 154

…IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI BENCH: ‘D’ NEW DELHI BEFORE SHRI G.S. PANNU, HON’BLE PRESIDENT AND SHRI SAKTIJIT DEY, HON’BLE VICE-PRESIDENT Assessment Year: 2010-11 With Assessment Year: 2011-12 With Assessment Year: 2010-11 Aluminium Pechiney, Vs. DCIT, C/o- CA, Praveen Gambhir, Circle-1(1)(1), 87-B, Masjid Moth Ph-2, International Taxation, DDA Flats, G.K. 3, New Delhi New Delhi PAN :AAICA3338C (Appellant) (Respondent) Assessee by Sh. Praveen Gambhir, CA Department by Sh. Sanjay Kumar, Sr. DR Sh. Mrinal Kr. Das, Sr. DR Date of hearing 09.06.2023 Date of pronouncement 06.09.2023 ORDER Captioned a…

M/S Aluminium Pechiney, New Delhi vs. DCIT (International Taxation), New Delhi

In the result, appeal is dismissed

ITA 3410/DEL/2016[2010-11]Status: DisposedITAT Delhi06 Sept 2023AY 2010-11

Bench: Shri G.S. Pannu, Hon’Ble & Shri Saktijit Dey, Hon’Ble Vice-Assessment Year: 2010-11 With Assessment Year: 2011-12 With Assessment Year: 2010-11 Aluminium Pechiney, Vs. Dcit, C/O- Ca, Praveen Gambhir, Circle-1(1)(1), 87-B, Masjid Moth Ph-2, International Taxation, Dda Flats, G.K. 3, New Delhi New Delhi Pan :Aaica3338C (Appellant) (Respondent)

Section 143(3)Section 154

…IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI BENCH: ‘D’ NEW DELHI BEFORE SHRI G.S. PANNU, HON’BLE PRESIDENT AND SHRI SAKTIJIT DEY, HON’BLE VICE-PRESIDENT Assessment Year: 2010-11 With Assessment Year: 2011-12 With Assessment Year: 2010-11 Aluminium Pechiney, Vs. DCIT, C/o- CA, Praveen Gambhir, Circle-1(1)(1), 87-B, Masjid Moth Ph-2, International Taxation, DDA Flats, G.K. 3, New Delhi New Delhi PAN :AAICA3338C (Appellant) (Respondent) Assessee by Sh. Praveen Gambhir, CA Department by Sh. Sanjay Kumar, Sr. DR Sh. Mrinal Kr. Das, Sr. DR Date of hearing 09.06.2023 Date of pronouncement 06.09.2023 ORDER Captioned a…