DDIT v. Preroy A.G

39 SOT 187Income Tax Appellate Tribunal2010#5273 most cited

What is DDIT v. Preroy A.G authority for?

The interpretation of the phrase "make available" in tax treaties hinges on whether services are accessible to the recipient without dependence on the provider for ongoing support.

22

judgments rely on this decision, according to BharatTax’s citation analysis of 366,005 Indian tax judgments — from 2016 to 2023.

Also referred to as

DDIT v Preroy A.G · make available clause · fees for included services · tax treaty · interpretation of treaty

Issues it is cited on

make available clausecopyrighted articlefees for included servicesretrospective amendmentroyalty incomesection 9(1)(vi)section 9(1)(vii)computer softwareenduring benefitfees for technical servicestax treatysection 9(1)

Judgments citing DDIT v. Preroy A.G

ACIT (It) 3(1)(1), Mumbai vs. Juniper Networks International B.V., Mumbai

Appeal of the revenue is dismissed

ITA 1592/MUM/2021[2013-14]Status: DisposedITAT Mumbai26 Sept 2023AY 2013-14

Bench: Shri Vikas Awasthy() & Ms. Padmavathy S. ()

…the interpretation of the words "make available", 30. The above principle was also relied upon by the Courts in the below judicial precedents  CIT v De Beers India Minerals Private Limited [2012] 346 1TR 467 (Kamataka High Court  DDIT v Preroy A.G [201 0] 39 SOT 187 (Mumbai ITAT). 31. From the perusal of SSSA we notice that the Juniper Services are made available to SSS on annual basis which would mean that the services are renewed every year. Therefore it cannot be said that SSS are able to carry out the services on their own without depending on the support of the assessee for resolving the issues arising…

ACIT (It) 3(1) (1), Mumbai vs. M/S. Juniper Networks Int. B.V., Mumbai

Appeal of the revenue is dismissed

ITA 1591/MUM/2021[2016-17]Status: DisposedITAT Mumbai26 Sept 2023AY 2016-17

Bench: Shri Vikas Awasthy() & Ms. Padmavathy S. ()

…the interpretation of the words "make available", 30. The above principle was also relied upon by the Courts in the below judicial precedents  CIT v De Beers India Minerals Private Limited [2012] 346 1TR 467 (Kamataka High Court  DDIT v Preroy A.G [201 0] 39 SOT 187 (Mumbai ITAT). 31. From the perusal of SSSA we notice that the Juniper Services are made available to SSS on annual basis which would mean that the services are renewed every year. Therefore it cannot be said that SSS are able to carry out the services on their own without depending on the support of the assessee for resolving the issues arising…

Asstt. CIT (It)-3(1)(1), Mumbai vs. M/S. Juniper Networks International B.V, Mumbai

Appeal of the revenue is dismissed

ITA 1333/MUM/2021[2015-16]Status: DisposedITAT Mumbai26 Sept 2023AY 2015-16

Bench: Shri Vikas Awasthy() & Ms. Padmavathy S. ()

…the interpretation of the words "make available", 30. The above principle was also relied upon by the Courts in the below judicial precedents  CIT v De Beers India Minerals Private Limited [2012] 346 1TR 467 (Kamataka High Court  DDIT v Preroy A.G [201 0] 39 SOT 187 (Mumbai ITAT). 31. From the perusal of SSSA we notice that the Juniper Services are made available to SSS on annual basis which would mean that the services are renewed every year. Therefore it cannot be said that SSS are able to carry out the services on their own without depending on the support of the assessee for resolving the issues arising…

M/S. United Airlines Inc., New Delhi vs. DDIT, New Delhi

ITA 958/DEL/2014[2002-03]Status: DisposedITAT Delhi12 Apr 2022AY 2002-03

Bench: Shri Saktijit Dey & Shri Pradip Kumar Kediaassessment Year: 1996-97 & Assessment Year: 1997-98 & Assessment Year: 1998-99 & Assessment Year: 1999-00 & Assessment Year: 2000-01 & Assessment Year: 2001-02 & Assessment Year: 2002-03 United Airlines, Vs. Dcit/Ddit Amba Deep Building, Non-Resident Circle, 14, K.G. Marg, New Delhi New Delhi Pan : Aaacu4427C (Appellant) (Respondent)

Section 142(1)(i)Section 271(1)(c)

…lines (supra), he submitted, technical explanation given by one of the Treaty partners, i.e., US Treasure Department could be used as an aid to interpretation. In this context, he also referred to a decision of the Tribunal in case of DDIT Vs. Preroy A.G., 39 SOT 187 (Mum.). Thus, he submitted, while interpreting Article 8 of the India–USA Tax Treaty, reliance can be placed on the OECD Commentary and Technical Explanation to the US Model Convention issued by the Treasure Department of US. To buttress his submission that all ancillary and incidental activities relating to operation of airlines in internation…

M/S. United Airlines Inc., New Delhi vs. DDIT, New Delhi

ITA 957/DEL/2014[2001-02]Status: DisposedITAT Delhi12 Apr 2022AY 2001-02

Bench: Shri Saktijit Dey & Shri Pradip Kumar Kediaassessment Year: 1996-97 & Assessment Year: 1997-98 & Assessment Year: 1998-99 & Assessment Year: 1999-00 & Assessment Year: 2000-01 & Assessment Year: 2001-02 & Assessment Year: 2002-03 United Airlines, Vs. Dcit/Ddit Amba Deep Building, Non-Resident Circle, 14, K.G. Marg, New Delhi New Delhi Pan : Aaacu4427C (Appellant) (Respondent)

Section 142(1)(i)Section 271(1)(c)

…lines (supra), he submitted, technical explanation given by one of the Treaty partners, i.e., US Treasure Department could be used as an aid to interpretation. In this context, he also referred to a decision of the Tribunal in case of DDIT Vs. Preroy A.G., 39 SOT 187 (Mum.). Thus, he submitted, while interpreting Article 8 of the India–USA Tax Treaty, reliance can be placed on the OECD Commentary and Technical Explanation to the US Model Convention issued by the Treasure Department of US. To buttress his submission that all ancillary and incidental activities relating to operation of airlines in internation…

M/S. United Airlines Inc., New Delhi vs. DDIT, New Delhi

ITA 956/DEL/2014[2000-01]Status: DisposedITAT Delhi12 Apr 2022AY 2000-01

Bench: Shri Saktijit Dey & Shri Pradip Kumar Kediaassessment Year: 1996-97 & Assessment Year: 1997-98 & Assessment Year: 1998-99 & Assessment Year: 1999-00 & Assessment Year: 2000-01 & Assessment Year: 2001-02 & Assessment Year: 2002-03 United Airlines, Vs. Dcit/Ddit Amba Deep Building, Non-Resident Circle, 14, K.G. Marg, New Delhi New Delhi Pan : Aaacu4427C (Appellant) (Respondent)

Section 142(1)(i)Section 271(1)(c)

…lines (supra), he submitted, technical explanation given by one of the Treaty partners, i.e., US Treasure Department could be used as an aid to interpretation. In this context, he also referred to a decision of the Tribunal in case of DDIT Vs. Preroy A.G., 39 SOT 187 (Mum.). Thus, he submitted, while interpreting Article 8 of the India–USA Tax Treaty, reliance can be placed on the OECD Commentary and Technical Explanation to the US Model Convention issued by the Treasure Department of US. To buttress his submission that all ancillary and incidental activities relating to operation of airlines in internation…

M/S. United Airlines Inc., New Delhi vs. DDIT, New Delhi

ITA 955/DEL/2014[1999-00]Status: DisposedITAT Delhi12 Apr 2022AY 1999-00

Bench: Shri Saktijit Dey & Shri Pradip Kumar Kediaassessment Year: 1996-97 & Assessment Year: 1997-98 & Assessment Year: 1998-99 & Assessment Year: 1999-00 & Assessment Year: 2000-01 & Assessment Year: 2001-02 & Assessment Year: 2002-03 United Airlines, Vs. Dcit/Ddit Amba Deep Building, Non-Resident Circle, 14, K.G. Marg, New Delhi New Delhi Pan : Aaacu4427C (Appellant) (Respondent)

Section 142(1)(i)Section 271(1)(c)

…lines (supra), he submitted, technical explanation given by one of the Treaty partners, i.e., US Treasure Department could be used as an aid to interpretation. In this context, he also referred to a decision of the Tribunal in case of DDIT Vs. Preroy A.G., 39 SOT 187 (Mum.). Thus, he submitted, while interpreting Article 8 of the India–USA Tax Treaty, reliance can be placed on the OECD Commentary and Technical Explanation to the US Model Convention issued by the Treasure Department of US. To buttress his submission that all ancillary and incidental activities relating to operation of airlines in internation…

M/S. United Airlines Inc., New Delhi vs. DDIT, New Delhi

ITA 954/DEL/2014[1998-99]Status: DisposedITAT Delhi12 Apr 2022AY 1998-99

Bench: Shri Saktijit Dey & Shri Pradip Kumar Kediaassessment Year: 1996-97 & Assessment Year: 1997-98 & Assessment Year: 1998-99 & Assessment Year: 1999-00 & Assessment Year: 2000-01 & Assessment Year: 2001-02 & Assessment Year: 2002-03 United Airlines, Vs. Dcit/Ddit Amba Deep Building, Non-Resident Circle, 14, K.G. Marg, New Delhi New Delhi Pan : Aaacu4427C (Appellant) (Respondent)

Section 142(1)(i)Section 271(1)(c)

…lines (supra), he submitted, technical explanation given by one of the Treaty partners, i.e., US Treasure Department could be used as an aid to interpretation. In this context, he also referred to a decision of the Tribunal in case of DDIT Vs. Preroy A.G., 39 SOT 187 (Mum.). Thus, he submitted, while interpreting Article 8 of the India–USA Tax Treaty, reliance can be placed on the OECD Commentary and Technical Explanation to the US Model Convention issued by the Treasure Department of US. To buttress his submission that all ancillary and incidental activities relating to operation of airlines in internation…

United Airlines vs. DDIT Non- Resident, Circle

ITA 1695/DEL/2008[2002-2003]Status: DisposedITAT Delhi12 Apr 2022AY 2002-2003

Bench: Shri Saktijit Dey & Shri Pradip Kumar Kediaassessment Year: 1996-97 & Assessment Year: 1997-98 & Assessment Year: 1998-99 & Assessment Year: 1999-00 & Assessment Year: 2000-01 & Assessment Year: 2001-02 & Assessment Year: 2002-03 United Airlines, Vs. Dcit/Ddit Amba Deep Building, Non-Resident Circle, 14, K.G. Marg, New Delhi New Delhi Pan : Aaacu4427C (Appellant) (Respondent)

Section 142(1)(i)Section 271(1)(c)

…lines (supra), he submitted, technical explanation given by one of the Treaty partners, i.e., US Treasure Department could be used as an aid to interpretation. In this context, he also referred to a decision of the Tribunal in case of DDIT Vs. Preroy A.G., 39 SOT 187 (Mum.). Thus, he submitted, while interpreting Article 8 of the India–USA Tax Treaty, reliance can be placed on the OECD Commentary and Technical Explanation to the US Model Convention issued by the Treasure Department of US. To buttress his submission that all ancillary and incidental activities relating to operation of airlines in internation…

United Airlines vs. DDIT Non- Resident, Circle

ITA 1694/DEL/2008[2001-2002]Status: DisposedITAT Delhi12 Apr 2022AY 2001-2002

Bench: Shri Saktijit Dey & Shri Pradip Kumar Kediaassessment Year: 1996-97 & Assessment Year: 1997-98 & Assessment Year: 1998-99 & Assessment Year: 1999-00 & Assessment Year: 2000-01 & Assessment Year: 2001-02 & Assessment Year: 2002-03 United Airlines, Vs. Dcit/Ddit Amba Deep Building, Non-Resident Circle, 14, K.G. Marg, New Delhi New Delhi Pan : Aaacu4427C (Appellant) (Respondent)

Section 142(1)(i)Section 271(1)(c)

…lines (supra), he submitted, technical explanation given by one of the Treaty partners, i.e., US Treasure Department could be used as an aid to interpretation. In this context, he also referred to a decision of the Tribunal in case of DDIT Vs. Preroy A.G., 39 SOT 187 (Mum.). Thus, he submitted, while interpreting Article 8 of the India–USA Tax Treaty, reliance can be placed on the OECD Commentary and Technical Explanation to the US Model Convention issued by the Treasure Department of US. To buttress his submission that all ancillary and incidental activities relating to operation of airlines in internation…

United Airlines vs. DDIT Non- Resident, Circle

ITA 1693/DEL/2008[2000-2001]Status: DisposedITAT Delhi12 Apr 2022AY 2000-2001

Bench: Shri Saktijit Dey & Shri Pradip Kumar Kediaassessment Year: 1996-97 & Assessment Year: 1997-98 & Assessment Year: 1998-99 & Assessment Year: 1999-00 & Assessment Year: 2000-01 & Assessment Year: 2001-02 & Assessment Year: 2002-03 United Airlines, Vs. Dcit/Ddit Amba Deep Building, Non-Resident Circle, 14, K.G. Marg, New Delhi New Delhi Pan : Aaacu4427C (Appellant) (Respondent)

Section 142(1)(i)Section 271(1)(c)

…lines (supra), he submitted, technical explanation given by one of the Treaty partners, i.e., US Treasure Department could be used as an aid to interpretation. In this context, he also referred to a decision of the Tribunal in case of DDIT Vs. Preroy A.G., 39 SOT 187 (Mum.). Thus, he submitted, while interpreting Article 8 of the India–USA Tax Treaty, reliance can be placed on the OECD Commentary and Technical Explanation to the US Model Convention issued by the Treasure Department of US. To buttress his submission that all ancillary and incidental activities relating to operation of airlines in internation…

United Airlines vs. DDIT Non- Resident, Circle

ITA 1692/DEL/2008[1999-2000]Status: DisposedITAT Delhi12 Apr 2022AY 1999-2000

Bench: Shri Saktijit Dey & Shri Pradip Kumar Kediaassessment Year: 1996-97 & Assessment Year: 1997-98 & Assessment Year: 1998-99 & Assessment Year: 1999-00 & Assessment Year: 2000-01 & Assessment Year: 2001-02 & Assessment Year: 2002-03 United Airlines, Vs. Dcit/Ddit Amba Deep Building, Non-Resident Circle, 14, K.G. Marg, New Delhi New Delhi Pan : Aaacu4427C (Appellant) (Respondent)

Section 142(1)(i)Section 271(1)(c)

…lines (supra), he submitted, technical explanation given by one of the Treaty partners, i.e., US Treasure Department could be used as an aid to interpretation. In this context, he also referred to a decision of the Tribunal in case of DDIT Vs. Preroy A.G., 39 SOT 187 (Mum.). Thus, he submitted, while interpreting Article 8 of the India–USA Tax Treaty, reliance can be placed on the OECD Commentary and Technical Explanation to the US Model Convention issued by the Treasure Department of US. To buttress his submission that all ancillary and incidental activities relating to operation of airlines in internation…

United Airlines vs. DDIT Non- Resident, Circle

ITA 1691/DEL/2008[1998-1999]Status: DisposedITAT Delhi12 Apr 2022AY 1998-1999

Bench: Shri Saktijit Dey & Shri Pradip Kumar Kediaassessment Year: 1996-97 & Assessment Year: 1997-98 & Assessment Year: 1998-99 & Assessment Year: 1999-00 & Assessment Year: 2000-01 & Assessment Year: 2001-02 & Assessment Year: 2002-03 United Airlines, Vs. Dcit/Ddit Amba Deep Building, Non-Resident Circle, 14, K.G. Marg, New Delhi New Delhi Pan : Aaacu4427C (Appellant) (Respondent)

Section 142(1)(i)Section 271(1)(c)

…lines (supra), he submitted, technical explanation given by one of the Treaty partners, i.e., US Treasure Department could be used as an aid to interpretation. In this context, he also referred to a decision of the Tribunal in case of DDIT Vs. Preroy A.G., 39 SOT 187 (Mum.). Thus, he submitted, while interpreting Article 8 of the India–USA Tax Treaty, reliance can be placed on the OECD Commentary and Technical Explanation to the US Model Convention issued by the Treasure Department of US. To buttress his submission that all ancillary and incidental activities relating to operation of airlines in internation…

United Airlines vs. DCIT, Non Resident Cir

ITA 217/DEL/2000[1997-1998]Status: DisposedITAT Delhi12 Apr 2022AY 1997-1998

Bench: Shri Saktijit Dey & Shri Pradip Kumar Kediaassessment Year: 1996-97 & Assessment Year: 1997-98 & Assessment Year: 1998-99 & Assessment Year: 1999-00 & Assessment Year: 2000-01 & Assessment Year: 2001-02 & Assessment Year: 2002-03 United Airlines, Vs. Dcit/Ddit Amba Deep Building, Non-Resident Circle, 14, K.G. Marg, New Delhi New Delhi Pan : Aaacu4427C (Appellant) (Respondent)

Section 142(1)(i)Section 271(1)(c)

…lines (supra), he submitted, technical explanation given by one of the Treaty partners, i.e., US Treasure Department could be used as an aid to interpretation. In this context, he also referred to a decision of the Tribunal in case of DDIT Vs. Preroy A.G., 39 SOT 187 (Mum.). Thus, he submitted, while interpreting Article 8 of the India–USA Tax Treaty, reliance can be placed on the OECD Commentary and Technical Explanation to the US Model Convention issued by the Treasure Department of US. To buttress his submission that all ancillary and incidental activities relating to operation of airlines in internation…

United Airlines vs. DCIT, Non Resident Cir

ITA 216/DEL/2000[1996-1997]Status: DisposedITAT Delhi12 Apr 2022AY 1996-1997

Bench: Shri Saktijit Dey & Shri Pradip Kumar Kediaassessment Year: 1996-97 & Assessment Year: 1997-98 & Assessment Year: 1998-99 & Assessment Year: 1999-00 & Assessment Year: 2000-01 & Assessment Year: 2001-02 & Assessment Year: 2002-03 United Airlines, Vs. Dcit/Ddit Amba Deep Building, Non-Resident Circle, 14, K.G. Marg, New Delhi New Delhi Pan : Aaacu4427C (Appellant) (Respondent)

Section 142(1)(i)Section 271(1)(c)

…lines (supra), he submitted, technical explanation given by one of the Treaty partners, i.e., US Treasure Department could be used as an aid to interpretation. In this context, he also referred to a decision of the Tribunal in case of DDIT Vs. Preroy A.G., 39 SOT 187 (Mum.). Thus, he submitted, while interpreting Article 8 of the India–USA Tax Treaty, reliance can be placed on the OECD Commentary and Technical Explanation to the US Model Convention issued by the Treasure Department of US. To buttress his submission that all ancillary and incidental activities relating to operation of airlines in internation…

Biocon Research Limited, Bangalore vs. CIT(A) I, Bangalore

In the result, the appeal filed by the revenue is dismissed

ITA 1329/BANG/2016[2012-13]Status: DisposedITAT Bangalore18 Dec 2017AY 2012-13

Bench: Shri Vijay Pal Rao & Shri Inturi Rama Rao

For Appellant: Shri Padamchand Khincha, CAFor Respondent: Shri R.N.Parbat, CIT(DR)
Section 10ASection 143(3)Section 14ASection 194CSection 40

…language) used. The above view has been affirmed by the subsequent pronouncements in the following cases: (a) National Organic Chemicals Industries Ltd v. Dy. CIT [2006] 5 SOT 317. (b) CESC v. CIT [2003] 87 ITD 653 (Kol.)(TM). (c) Dy. DIT v Preroy A.G. [2010] 39 SOT 187 (Mum.) (d) Intertek Testing Services India (P.) Ltd., In re [2008] 307 ITR 418/175 Taxman 375 (AAR) ITA Nos.1229, 1329, 1250 & 1251/Bang/2016 Page 56 MEANING OF THE TERM 'MAKE AVAILABLE' Under the MoU to India-US tax treaty, it has been clarified that: "Generally speaking, technology will be considered "made available" when the person acquiring t…

DCIT, Bangalore vs. M/S Biocon Research Ltd., Bangalore

In the result, the appeal filed by the revenue is dismissed

ITA 1251/BANG/2016[2012-13]Status: DisposedITAT Bangalore18 Dec 2017AY 2012-13

Bench: Shri Vijay Pal Rao & Shri Inturi Rama Rao

For Appellant: Shri Padamchand Khincha, CAFor Respondent: Shri R.N.Parbat, CIT(DR)
Section 10ASection 143(3)Section 14ASection 194CSection 40

…language) used. The above view has been affirmed by the subsequent pronouncements in the following cases: (a) National Organic Chemicals Industries Ltd v. Dy. CIT [2006] 5 SOT 317. (b) CESC v. CIT [2003] 87 ITD 653 (Kol.)(TM). (c) Dy. DIT v Preroy A.G. [2010] 39 SOT 187 (Mum.) (d) Intertek Testing Services India (P.) Ltd., In re [2008] 307 ITR 418/175 Taxman 375 (AAR) ITA Nos.1229, 1329, 1250 & 1251/Bang/2016 Page 56 MEANING OF THE TERM 'MAKE AVAILABLE' Under the MoU to India-US tax treaty, it has been clarified that: "Generally speaking, technology will be considered "made available" when the person acquiring t…

DCIT, Bangalore vs. M/S Biocon Research Ltd., Bangalore

In the result, the appeal filed by the revenue is dismissed

ITA 1250/BANG/2016[2011-12]Status: DisposedITAT Bangalore18 Dec 2017AY 2011-12

Bench: Shri Vijay Pal Rao & Shri Inturi Rama Rao

For Appellant: Shri Padamchand Khincha, CAFor Respondent: Shri R.N.Parbat, CIT(DR)
Section 10ASection 143(3)Section 14ASection 194CSection 40

…language) used. The above view has been affirmed by the subsequent pronouncements in the following cases: (a) National Organic Chemicals Industries Ltd v. Dy. CIT [2006] 5 SOT 317. (b) CESC v. CIT [2003] 87 ITD 653 (Kol.)(TM). (c) Dy. DIT v Preroy A.G. [2010] 39 SOT 187 (Mum.) (d) Intertek Testing Services India (P.) Ltd., In re [2008] 307 ITR 418/175 Taxman 375 (AAR) ITA Nos.1229, 1329, 1250 & 1251/Bang/2016 Page 56 MEANING OF THE TERM 'MAKE AVAILABLE' Under the MoU to India-US tax treaty, it has been clarified that: "Generally speaking, technology will be considered "made available" when the person acquiring t…

Biocon Research Limited, Bangalore vs. CIT(A) I, Bangalore

In the result, the appeal filed by the revenue is dismissed

ITA 1229/BANG/2016[2011-12]Status: DisposedITAT Bangalore18 Dec 2017AY 2011-12

Bench: Shri Vijay Pal Rao & Shri Inturi Rama Rao

For Appellant: Shri Padamchand Khincha, CAFor Respondent: Shri R.N.Parbat, CIT(DR)
Section 10ASection 143(3)Section 14ASection 194CSection 40

…language) used. The above view has been affirmed by the subsequent pronouncements in the following cases: (a) National Organic Chemicals Industries Ltd v. Dy. CIT [2006] 5 SOT 317. (b) CESC v. CIT [2003] 87 ITD 653 (Kol.)(TM). (c) Dy. DIT v Preroy A.G. [2010] 39 SOT 187 (Mum.) (d) Intertek Testing Services India (P.) Ltd., In re [2008] 307 ITR 418/175 Taxman 375 (AAR) ITA Nos.1229, 1329, 1250 & 1251/Bang/2016 Page 56 MEANING OF THE TERM 'MAKE AVAILABLE' Under the MoU to India-US tax treaty, it has been clarified that: "Generally speaking, technology will be considered "made available" when the person acquiring t…

Outotec Oyj, Kolkata vs. DCIT, International Taxation 2(1), Kolkata

In the result, both the appeals of the assessee are allowed

ITA 462/KOL/2015[2011-2012]Status: DisposedITAT Kolkata14 Oct 2016AY 2011-2012

Bench: Shri N. V. Vasudevan, Jm & Shri M. Balaganesh, Am]

For Appellant: Shri K.M. Gupta, Advocate &For Respondent: Shri G. Mallikarjuna, CIT, DR
Section 144C(5)

…eaty clarifies meaning of the terms (or language) used . Reliance is placed on the following decisions in this regard:- (a) National Organic Chemicals Industries Ltd vs DCIT reported in (2006) 5 SOT 317 (Mumbai ITAT) (b) DDIT vs Preroy A.G. reported in (2010) 39 SOT 187 (Mum ITAT) (c) Intertek Testing Services India (P) ltd In re reported in (2008) 307 ITR 418 (AAR – New Delhi) dated 7.11.2008 (d) ITO vs Nokia India (P) Ltd reported in (2015) 59 taxmann.com 120 (Delhi Trib) dated 8.7.2015 (e) Steria (India) ltd vs CIT reported in (2016) 386 ITR 390 (Del HC) 8.3. We find that the co-ordinate bench decision of thi…

DDIT v. Preroy A.G (39 SOT 187) — Cited in 22 Judgments | BharatTax