Bid Services Division (Mauritius) Ltd. v. Authority of Advance Ruling (Income-tax)

TFDAC IRELAND II LIMITED,IRELAND vs. DEPUTY COMMISSIONER OF INCOME TAX INTERNATIONAL TAX CIRCLE 4(1)(2) MUMBAI, MUMBAI

…ture whose ultimate ownership lies outside the jurisdiction of incorporation. Reliance in this regard was also placed on the judgment of the Hon‟ble Bombay High Court in Bid Services Division (Mauritius) Ltd. v. Authority of Advance Ruling (Income-tax) [2023] 453 ITR 461, wherein it was held that the mere presence of a parent in a tax-neutral jurisdiction is not, per se, proof of treaty abuse.\n25. He thus submitted that, the finding of the ld.DRP and AO that the assessee lacked operational infrastructure in Ireland is both factually inaccurate and legally untenable. In this specialised industry, it is common and…

DAE(SY22) LEASING (IRELAND)41, DESIGNATED ACTIVITY COMPANY ,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX INTERNATIONAL TAXATION CIRCLE 2(1)(2), MUMBAI

Bench: SHRI AMIT SHUKLA (Judicial Member), MS PADMAVATHY S (Accountant Member)

…IN THE INCOME TAX APPELLATE TRIBUNAL, „I‟ BENCH MUMBAI BEFORE: SHRI AMIT SHUKLA, JUDICIAL MEMBER & MS PADMAVATHY S, ACCOUNTANT MEMBER ITA No. AY Assessee/ Respondent Appellant ITA No. 2022-23 Sky High Appeal XLIII The Assistant 1122/Mum/2025 Leasing Company Commissioner Limited of Income Tax 2, Grand Canal Square (International Grand Canal Harbour Tax) Circle Dublin, D02 A342 4(2)(1), Ireland Mumbai C/o. DMD Advocates 30, Nizamuddin East, New Delhi-110 013 PAN: ABFCS0569K SA 2022-23 Sky High Appeal XLIII The Assistant No.38/Mum/2025 Leasing Company Commissioner (Arising out of Limited of Income Tax ITA No. 2,…

ORTUS AIRCRAFT LEASE 5( DUBLIN) LIMITED,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 3(2)(2) INTERNATIONAL TAXATION, MUMBAI

…ture whose ultimate ownership lies outside the jurisdiction of incorporation. Reliance in this regard was also placed on the judgment of the Hon‟ble Bombay High Court in Bid Services Division (Mauritius) Ltd. v. Authority of Advance Ruling (Income-tax) [2023] 453 ITR 461, wherein it was held that the mere presence of a parent in a tax-neutral jurisdiction is not, per se, proof of treaty abuse. 25. He thus submitted that, the finding of the ld.DRP and AO that the assessee lacked operational infrastructure in Ireland is both factually inaccurate and legally untenable. In this specialised industry, it is common and…

ORTUS AIRCRAFT LEASE 6(DUBLIN) LIMITED,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 3(2)(2) INTERNATIONAL TAXATION, MUMBAI

Bench: SHRI AMIT SHUKLA (Judicial Member), MS PADMAVATHY S (Accountant Member)

…IN THE INCOME TAX APPELLATE TRIBUNAL, „I‟ BENCH MUMBAI BEFORE: SHRI AMIT SHUKLA, JUDICIAL MEMBER & MS PADMAVATHY S, ACCOUNTANT MEMBER ITA No. AY Assessee/ Respondent Appellant ITA No. 2022-23 Sky High Appeal XLIII The Assistant 1122/Mum/2025 Leasing Company Commissioner Limited of Income Tax 2, Grand Canal Square (International Grand Canal Harbour Tax) Circle Dublin, D02 A342 4(2)(1), Ireland Mumbai C/o. DMD Advocates 30, Nizamuddin East, New Delhi-110 013 PAN: ABFCS0569K SA 2022-23 Sky High Appeal XLIII The Assistant No.38/Mum/2025 Leasing Company Commissioner (Arising out of Limited of Income Tax ITA No. 2,…