JP Morgan Chase Bank N.A v. DCIT

183 ITD 190Income Tax Appellate Tribunal2020#23245 most cited
3

judgments rely on this decision, according to BharatTax’s citation analysis of 366,339 Indian tax judgments — from 2023 to 2023.

Issues it is cited on

section 9(1)(v)section 195(1)section 144c(3)beneficial ownertax treatypermanent establishmentsection 195section 9(1)liable to taxsection 144cnon-residentsection 19

Judgments citing JP Morgan Chase Bank N.A v. DCIT

Deputy Commissioner of Income Tax (International Taxation)-2(1)(1), Mumbai vs. M/S Cooperative Babobank Ua., Mumbai

In the result, the appeal by the Revenue is partly allowed for statistical purposes

ITA 2978/MUM/2022[2015-2016]Status: DisposedITAT Mumbai21 Apr 2023AY 2015-2016

Bench: Shri Prashant Maharishi & Shri Sandeep Singh Karhail

For Appellant: Shri Nitesh JoshiFor Respondent: Shri Soumendu Kumar Dash
Section 250

…) of the Act vide Finance Act, 2015 w.e.f. 01/04/2016 by the AO, we find that the said amendment was held to be applicable prospectively from 01/04/2016 and not prior thereto by the coordinate bench of the Tribunal in JP Morgan Chase Bank N.A. vs DCIT, [2020] 183 ITD 190 (Mumbai - Trib.). Thus, this amendment is not applicable to the year under consideration and would only be applicable to the assessment year 2016-17 and onwards. Therefore, respectfully following the aforesaid judicial pronouncements, we find no infirmity in the impugned order passed by the learned CIT(A) on this issue. As a result, ground No. 5…

Deputy Comm. of Income Tax (Int Taxation)-2(1)(1), Mumbai vs. M/S Cooperative Rabobank Ua, Mumbai

In the result, the appeal by the Revenue is partly allowed for statistical purposes

ITA 2514/MUM/2022[2013-2014]Status: DisposedITAT Mumbai21 Apr 2023AY 2013-2014

Bench: Shri Prashant Maharishi & Shri Sandeep Singh Karhail

For Appellant: Shri Nitesh JoshiFor Respondent: Shri Soumendu Kumar Dash
Section 250

…) of the Act vide Finance Act, 2015 w.e.f. 01/04/2016 by the AO, we find that the said amendment was held to be applicable prospectively from 01/04/2016 and not prior thereto by the coordinate bench of the Tribunal in JP Morgan Chase Bank N.A. vs DCIT, [2020] 183 ITD 190 (Mumbai - Trib.). Thus, this amendment is not applicable to the year under consideration and would only be applicable to the assessment year 2016-17 and onwards. Therefore, respectfully following the aforesaid judicial pronouncements, we find no infirmity in the impugned order passed by the learned CIT(A) on this issue. As a result, ground No. 5…

Deputy Comm. of Income Tax (Int Taxation)-2(1)(1), Mumbai vs. M/S Cooperative Rabobank Ua, Mumbai

In the result, the appeal by the Revenue is partly allowed for statistical purposes

ITA 2513/MUM/2022[2014-2015]Status: DisposedITAT Mumbai21 Apr 2023AY 2014-2015

Bench: Shri Prashant Maharishi & Shri Sandeep Singh Karhail

For Appellant: Shri Nitesh JoshiFor Respondent: Shri Soumendu Kumar Dash
Section 250

…) of the Act vide Finance Act, 2015 w.e.f. 01/04/2016 by the AO, we find that the said amendment was held to be applicable prospectively from 01/04/2016 and not prior thereto by the coordinate bench of the Tribunal in JP Morgan Chase Bank N.A. vs DCIT, [2020] 183 ITD 190 (Mumbai - Trib.). Thus, this amendment is not applicable to the year under consideration and would only be applicable to the assessment year 2016-17 and onwards. Therefore, respectfully following the aforesaid judicial pronouncements, we find no infirmity in the impugned order passed by the learned CIT(A) on this issue. As a result, ground No. 5…

JP Morgan Chase Bank N.A v. DCIT (183 ITD 190) — Cited in 3 Judgments | BharatTax