ADIT v. Universal\nInternational Music BV

ACIT, CIRCLE-4(2), NEW DELHI vs. BHARTI AIRTEL LTD., NEW DELHI

Appeal of the assessee is allowed

…tate, thus, the assessee had no reason to doubt or dispute the same.\nIn support of his submissions, the Id. Counsel placed reliance on CBDT Circular no.\n789 dated 13.04.2000 and the decision rendered in the case of ADIT vs Universal\nInternational Music BV, 141 TTJ 364 (Mumbai). The Id. Counsel for the assessee\nfurther submitted that considering TRCs issued by Swedish Tax Authorities, the\nassessee was under bonafide belief that the taxability of payments made to ABN\nAmro was to be determined with reference to the provisions of Article 11 of the\nIndo-Sweden DTAA, to the extent it was more beneficial as compa…

ACIT, CIRCLE-4(2), NEW DELHI vs. BHARTI AIRTEL LTD., NEW DELHI

Appeal of the assessee is allowed

…tate, thus, the assessee had no reason to doubt or dispute the same.\nIn support of his submissions, the Id. Counsel placed reliance on CBDT Circular no.\n789 dated 13.04.2000 and the decision rendered in the case of ADIT vs Universal\nInternational Music BV, 141 TTJ 364 (Mumbai). The Id. Counsel for the assessee\nfurther submitted that considering TRCs issued by Swedish Tax Authorities, the\nassessee was under bonafide belief that the taxability of payments made to ABN\nAmro was to be determined with reference to the provisions of Article 11 of the\nIndo-Sweden DTAA, to the extent it was more beneficial as compa…

BHARTI AIRTEL LIMITED,NEW DELHI vs. ACIT CIRCLE 4(2), NEW DELHI

The appeal of the Revenue is partly allowed and appeal of the assessee is allowed

Bench: Shri Vikas Awasthy& Shri Amitabh Shuklaआअसं.5692 और5693/िद"ी /2019(िन.व. 2007-08 और2008-09)

…g State, thus, the assessee had no reason to doubt or dispute the same. In support of his submissions, the ld. Counsel placed reliance on CBDT Circular no. 789 dated 13.04.2000 and the decision rendered in the case of ADIT vs Universal International Music BV, 141 TTJ 364 (Mumbai). The ld. Counsel for the assessee further submitted that considering TRCs issued by Swedish Tax Authorities, the assessee was under bonafide belief that the taxability of payments made to ABN Amro was to be determined with reference to the provisions of Article 11 of the Indo-Sweden DTAA, to the extent it was more beneficial as compared…

BHARTI AIRTEL LTD,NEW DELHI vs. ACIT CIRCLE 4(2), NEW DELHI

Appeal of the assessee is allowed

…tate, thus, the assessee had no reason to doubt or dispute the same.\nIn support of his submissions, the Id. Counsel placed reliance on CBDT Circular no.\n789 dated 13.04.2000 and the decision rendered in the case of ADIT vs Universal\nInternational Music BV, 141 TTJ 364 (Mumbai). The Id. Counsel for the assessee\nfurther submitted that considering TRCs issued by Swedish Tax Authorities, the\nassessee was under bonafide belief that the taxability of payments made to ABN\nAmro was to be determined with reference to the provisions of Article 11 of the\nIndo-Sweden DTAA, to the extent it was more beneficial as compa…