New India Insurance v. ACIT

18 SOT 51Income Tax Appellate Tribunal2007#2729 most cited

What is New India Insurance v. ACIT authority for?

A specific deduction claimed by a foreign banking company is not allowable, as this issue has been decided against the assessee by the ITAT Special Bench.

43

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2016 to 2025.

Also referred to as

New India Insurance v. ACIT · 18 SOT 51 · ITAT Special Bench · deduction foreign banking company · disallowance · non-resident banking company · section 5(2) · section 115A · Income Tax Act 1961

Sections most often in play

Section 1961 Section 5(2)Section 115A Section 143(3)Section 144C(13)Section 234B Section 234D Section 244A

Issues it is cited on

section 9(1)(v)section 92ca(3a)section 3a section 35dda section 92c(1)section 44c use of equipment section 35dd section 36(2)(v)section 4a section 61 section 46

Judgments citing New India Insurance v. ACIT

CREDIT AGRICOLE CORPORATE AND INVESTMENT BANK,MUMBAI vs. THE DY-CIT (INT. TAXATION)-2(1)(1), MUMBAI

Accordingly these grounds are dismissed as not pressed

ITA 749/MUM/2022[2017-18]Status: DisposedITAT Mumbai20 Mar 2025AY 2017-18

Bench: Smt Beena Pillai, Jm & Ms Padmavathy S, Am I.T. (Tp) A. No. 1479/Mum/2015 (Assessment Year: 2010-11) Credit Agricole Corporate & Dcit (International Taxation)- Investment Bank (Formerly 2(1)(1), 1St Floor, Room No. 136, Known As ‘Calyon Bank’) Vs. 11Th Floor, Hoechst House, Scindia House, N.M. Marg, Nariman Point, Mumbai-400021. Ballard Pier, Mumbai-400038. Pan: Aaccc3872B Appellant) : Respondent)

…ing company. The CIT(A) has confirmed disallowance made by the AO, when the assessee itself has fairly conceded that this issue is now covered against the assessee by the decision of special bench of this Tribunal in case of New India Industries Ltd. V. ACIT (18 SOT 51) as well as the decision coordinate Bench in case of Ahmadabad and Gujarat Gas Financial Services Ltd. V. ACIT (307 ITR 370). 45. Before us, the learned AR has fairly conceded that this issue is covered against the assessee by the decision of the Special Bench of this Tribunal. Accordingly, we decide this issue against the assessee and in favour of…

CREDIT AGRICOLE CORPORATE & INVESTMENT BANK,MUMBAI vs. THE DY.CIT OF INCOME TAX (INTERNATIONSL TAXATION) -2(1) (1) , MUMBAI

Accordingly these grounds are dismissed as not pressed

ITA 1234/MUM/2022[2018-19]Status: DisposedITAT Mumbai20 Mar 2025AY 2018-19

Bench: Smt Beena Pillai, Jm & Ms Padmavathy S, Am I.T. (Tp) A. No. 1479/Mum/2015 (Assessment Year: 2010-11) Credit Agricole Corporate & Dcit (International Taxation)- Investment Bank (Formerly 2(1)(1), 1St Floor, Room No. 136, Known As ‘Calyon Bank’) Vs. 11Th Floor, Hoechst House, Scindia House, N.M. Marg, Nariman Point, Mumbai-400021. Ballard Pier, Mumbai-400038. Pan: Aaccc3872B Appellant) : Respondent)

…ing company. The CIT(A) has confirmed disallowance made by the AO, when the assessee itself has fairly conceded that this issue is now covered against the assessee by the decision of special bench of this Tribunal in case of New India Industries Ltd. V. ACIT (18 SOT 51) as well as the decision coordinate Bench in case of Ahmadabad and Gujarat Gas Financial Services Ltd. V. ACIT (307 ITR 370). 45. Before us, the learned AR has fairly conceded that this issue is covered against the assessee by the decision of the Special Bench of this Tribunal. Accordingly, we decide this issue against the assessee and in favour of…

CREDIT AGRICOLE CORPORATE & INVESTMENT BANK,MUMBAI vs. THE JT CIT (INTERNATIONAL TAXATIONA), MUMBAI

Accordingly these grounds are dismissed as not pressed

ITA 1027/MUM/2021[2016-17]Status: DisposedITAT Mumbai20 Mar 2025AY 2016-17

…company. The CIT(A) has confirmed\ndisallowance made by the AO, when the assessee itself has fairly conceded that this\nissue is now covered against the assessee by the decision of special bench of this\nTribunal in case of New India Industries Ltd. V. ACIT (18 SOT 51) as well as the\ndecision coordinate Bench in case of Ahmadabad and Gujarat Gas Financial\nServices Ltd. V. ACIT (307 ITR 370).\n45. Before us, the learned AR has fairly conceded that this issue is covered against\nthe assessee by the decision of the Special Bench of this Tribunal. Accordingly, we\ndecide this issue against the assessee and in favo…

CREDIT AGRICOLE CORPORATE AND INVESTMENT BANK,MUMBAI vs. ACIT (IT) 2 (1)(1), MUMBAI

Accordingly these grounds are dismissed as not pressed

ITA 458/MUM/2019[2014-15]Status: DisposedITAT Mumbai20 Mar 2025AY 2014-15

…company. The CIT(A) has confirmed\ndisallowance made by the AO, when the assessee itself has fairly conceded that this\nissue is now covered against the assessee by the decision of special bench of this\nTribunal in case of New India Industries Ltd. V. ACIT (18 SOT 51) as well as the\ndecision coordinate Bench in case of Ahmadabad and Gujarat Gas Financial\nServices Ltd. V. ACIT (307 ITR 370).\n45. Before us, the learned AR has fairly conceded that this issue is covered against\nthe assessee by the decision of the Special Bench of this Tribunal. Accordingly, we\ndecide this issue against the assessee and in favo…

CREDIT AGRICOLE CORPORATE AND INVESTMENT BANK,MUMBAI vs. DCIT (IT) 2(1)(1), MUMBAI

Accordingly these grounds are dismissed as not pressed

ITA 4652/MUM/2017[2013-14]Status: DisposedITAT Mumbai20 Mar 2025AY 2013-14

…company. The CIT(A) has confirmed\ndisallowance made by the AO, when the assessee itself has fairly conceded that this\nissue is now covered against the assessee by the decision of special bench of this\nTribunal in case of New India Industries Ltd. V. ACIT (18 SOT 51) as well as the\ndecision coordinate Bench in case of Ahmadabad and Gujarat Gas Financial\nServices Ltd. V. ACIT (307 ITR 370).\n45. Before us, the learned AR has fairly conceded that this issue is covered against\nthe assessee by the decision of the Special Bench of this Tribunal. Accordingly, we\ndecide this issue against the assessee and in favo…

CREDIT AGRICOLE CORPORATE AND INVESTMENT BANK,MUMBAI vs. DCIT (IT) 2(1)(1), MUMBAI

Accordingly these grounds are dismissed as not pressed

ITA 2313/MUM/2017[2012-13]Status: DisposedITAT Mumbai20 Mar 2025AY 2012-13

…company. The CIT(A) has confirmed\ndisallowance made by the AO, when the assessee itself has fairly conceded that this\nissue is now covered against the assessee by the decision of special bench of this\nTribunal in case of New India Industries Ltd. V. ACIT (18 SOT 51) as well as the\ndecision coordinate Bench in case of Ahmadabad and Gujarat Gas Financial\nServices Ltd. V. ACIT (307 ITR 370).\n45. Before us, the learned AR has fairly conceded that this issue is covered against\nthe assessee by the decision of the Special Bench of this Tribunal. Accordingly, we\ndecide this issue against the assessee and in favo…

CREDIT AGRICOLE CORPORATE AND INVESTMENT BANK,MUMBAI vs. DCIT (IT) 2(1)(1), MUMBAI

Accordingly these grounds are dismissed as not pressed

ITA 1273/MUM/2016[2011-12]Status: DisposedITAT Mumbai20 Mar 2025AY 2011-12

…company. The CIT(A) has confirmed\ndisallowance made by the AO, when the assessee itself has fairly conceded that this\nissue is now covered against the assessee by the decision of special bench of this\nTribunal in case of New India Industries Ltd. V. ACIT (18 SOT 51) as well as the\ndecision coordinate Bench in case of Ahmadabad and Gujarat Gas Financial\nServices Ltd. V. ACIT (307 ITR 370).\n45. Before us, the learned AR has fairly conceded that this issue is covered against\nthe assessee by the decision of the Special Bench of this Tribunal. Accordingly, we\ndecide this issue against the assessee and in favo…

DCIT (IT) 2(1)(1), MUMBAI vs. CREDIT AGRICOLE CORPORATE AND INVESTMENT BANK, MUMBAI

Accordingly these grounds are dismissed as not pressed

ITA 1165/MUM/2016[2011-12]Status: DisposedITAT Mumbai20 Mar 2025AY 2011-12

…company. The CIT(A) has confirmed\ndisallowance made by the AO, when the assessee itself has fairly conceded that this\nissue is now covered against the assessee by the decision of special bench of this\nTribunal in case of New India Industries Ltd. V. ACIT (18 SOT 51) as well as the\ndecision coordinate Bench in case of Ahmadabad and Gujarat Gas Financial\nServices Ltd. V. ACIT (307 ITR 370).\n45. Before us, the learned AR has fairly conceded that this issue is covered against\nthe assessee by the decision of the Special Bench of this Tribunal. Accordingly, we\ndecide this issue against the assessee and in favo…

ADIT (IT) 1(2), MUMBAI vs. CREDIT AGRICOLE CORPORATE AND INVESTMENT BANK, MUMBAI

Accordingly these grounds are dismissed as not pressed

ITA 1839/MUM/2015[2010-11]Status: DisposedITAT Mumbai20 Mar 2025AY 2010-11

Bench: Smt Beena Pillai, Jm & Ms Padmavathy S, Am I.T. (Tp) A. No. 1479/Mum/2015 (Assessment Year: 2010-11) Credit Agricole Corporate & Dcit (International Taxation)- Investment Bank (Formerly 2(1)(1), 1St Floor, Room No. 136, Known As ‘Calyon Bank’) Vs. 11Th Floor, Hoechst House, Scindia House, N.M. Marg, Nariman Point, Mumbai-400021. Ballard Pier, Mumbai-400038. Pan: Aaccc3872B Appellant) : Respondent)

…ing company. The CIT(A) has confirmed disallowance made by the AO, when the assessee itself has fairly conceded that this issue is now covered against the assessee by the decision of special bench of this Tribunal in case of New India Industries Ltd. V. ACIT (18 SOT 51) as well as the decision coordinate Bench in case of Ahmadabad and Gujarat Gas Financial Services Ltd. V. ACIT (307 ITR 370). 45. Before us, the learned AR has fairly conceded that this issue is covered against the assessee by the decision of the Special Bench of this Tribunal. Accordingly, we decide this issue against the assessee and in favour of…

CREDIT AGRICOLE CORPORATE AND INVESTMENT BANK,MUMBAI vs. DCIT (IT) 2(1)(1), MUMBAI

Accordingly these grounds are dismissed as not pressed

ITA 1479/MUM/2015[2010-11]Status: DisposedITAT Mumbai20 Mar 2025AY 2010-11

…company. The CIT(A) has confirmed\ndisallowance made by the AO, when the assessee itself has fairly conceded that this\nissue is now covered against the assessee by the decision of special bench of this\nTribunal in case of New India Industries Ltd. V. ACIT (18 SOT 51) as well as the\ndecision coordinate Bench in case of Ahmadabad and Gujarat Gas Financial\nServices Ltd. V. ACIT (307 ITR 370).\n45. Before us, the learned AR has fairly conceded that this issue is covered against\nthe assessee by the decision of the Special Bench of this Tribunal. Accordingly, we\ndecide this issue against the assessee and in favo…

DY. COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-4(4), MUMBAI, MUMBAI vs. ROMELL HOUSING LLP, MUMBAI

ITA 3935/MUM/2023[2018-19]Status: DisposedITAT Mumbai18 Oct 2024AY 2018-19

Bench: Shri Sandeep Singh Karhailshri Gagan Goyal

For Appellant: Shri Nitesh JoshiFor Respondent: Smt. Sanyogita Nagpal, CIT-DR

Section 142(1)Section 143(2)Section 143(3)Section 144BSection 250Section 253(4)Section 56(2)(x)

…n this case is13.04.2017. In the case of Southern Technologies Ltd vs JCIT, 187 Taxman 346 (SC), it was categorically held by Hon'ble SC that provisions of RBI cannot over-ride provisions of I-T Act. Similarly, in the case of New India Industries Ltd vs ACIT, 18 SOT 51, ITAT Delhi (Special Bench), it was held by Hon'ble Tribunal that other Acts cannot over-ride the provisions of the Income-tax Act. The argument that S.56(2)(x) does not apply to a case where the "the date of registration" is after 01.04.2017 is not borne out from the provisions of the Act and stands rejected." Being aggrieved, the assessee has rai…

THE ANDHRA PRADESH STATE CO-OPERATIVE BANK LTD,VIJAYAWADA vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-4(1), HYDERABAD

In the result, the S.As. filed by the assessee are dismissed

ITA 464/HYD/2023[2010-11]Status: DisposedITAT Hyderabad29 Jul 2024AY 2010-11

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

For Appellant: Shri M.V.Anil Kumar, AdvocateFor Respondent: : Ms. K. Haritha, CIT-DR

Section 36Section 36(1)(vii)Section 36(1)(viia)Section 37

…आयकर अपीलीय अधिकरण, हैदराबाद पीठ IN THE INCOME TAX APPELLATE TRIBUNAL Hyderabad ‘A’ Bench, Hyderabad BEFORE SHRI LALIET KUMAR, JUDICIAL MEMBER AND SHRI MADHUSUDAN SAWDIA, ACCOUNTANT MEMBER आ.अपी.सं /ITA Nos.1796/Hyd/2017,241/Hyd/2018, 464/Hyd/2023 & 460 to 463/Hyd/2023) (निर्धारण वर्ा/Assessment Years(“A.Ys.”): 2008-09 to 2014-15 ) & (S.A. Nos.63,67,64 to 66/Hyd/2023 ) (निर्धारण वर्ा/A.Ys: 2008-09, 2010-11, 2011-12, 2012-13 & 2014-15 ) The Andhra Pradesh State Co- Asst. Commissioner of Income Tax, Vs. Circle 4(1), Hyderabad. operative Bank Limited, Hyderabad. PAN: AAAAT2971J (Appellant) (Respondent) निर्धारर…

THE ANDHRA PRADESH STATE CO-OPERATIVE BANK LTD,VIJAYAWADA vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-4(1), HYDERABAD

In the result, the S.As. filed by the assessee are dismissed

ITA 463/HYD/2023[2014-15]Status: DisposedITAT Hyderabad29 Jul 2024AY 2014-15

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

For Appellant: Shri M.V.Anil Kumar, AdvocateFor Respondent: : Ms. K. Haritha, CIT-DR

Section 36Section 36(1)(vii)Section 36(1)(viia)Section 37

…आयकर अपीलीय अधिकरण, हैदराबाद पीठ IN THE INCOME TAX APPELLATE TRIBUNAL Hyderabad ‘A’ Bench, Hyderabad BEFORE SHRI LALIET KUMAR, JUDICIAL MEMBER AND SHRI MADHUSUDAN SAWDIA, ACCOUNTANT MEMBER आ.अपी.सं /ITA Nos.1796/Hyd/2017,241/Hyd/2018, 464/Hyd/2023 & 460 to 463/Hyd/2023) (निर्धारण वर्ा/Assessment Years(“A.Ys.”): 2008-09 to 2014-15 ) & (S.A. Nos.63,67,64 to 66/Hyd/2023 ) (निर्धारण वर्ा/A.Ys: 2008-09, 2010-11, 2011-12, 2012-13 & 2014-15 ) The Andhra Pradesh State Co- Asst. Commissioner of Income Tax, Vs. Circle 4(1), Hyderabad. operative Bank Limited, Hyderabad. PAN: AAAAT2971J (Appellant) (Respondent) निर्धारर…

THE ANDHRA PRADESH STATE CO-OPERATIVE BANK LTD,VIJAYAWADA vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-4(1), HYDERABAD

In the result, the S.As. filed by the assessee are dismissed

ITA 462/HYD/2023[2013-14]Status: DisposedITAT Hyderabad29 Jul 2024AY 2013-14

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

For Appellant: Shri M.V.Anil Kumar, AdvocateFor Respondent: : Ms. K. Haritha, CIT-DR

Section 36Section 36(1)(vii)Section 36(1)(viia)Section 37

…आयकर अपीलीय अधिकरण, हैदराबाद पीठ IN THE INCOME TAX APPELLATE TRIBUNAL Hyderabad ‘A’ Bench, Hyderabad BEFORE SHRI LALIET KUMAR, JUDICIAL MEMBER AND SHRI MADHUSUDAN SAWDIA, ACCOUNTANT MEMBER आ.अपी.सं /ITA Nos.1796/Hyd/2017,241/Hyd/2018, 464/Hyd/2023 & 460 to 463/Hyd/2023) (निर्धारण वर्ा/Assessment Years(“A.Ys.”): 2008-09 to 2014-15 ) & (S.A. Nos.63,67,64 to 66/Hyd/2023 ) (निर्धारण वर्ा/A.Ys: 2008-09, 2010-11, 2011-12, 2012-13 & 2014-15 ) The Andhra Pradesh State Co- Asst. Commissioner of Income Tax, Vs. Circle 4(1), Hyderabad. operative Bank Limited, Hyderabad. PAN: AAAAT2971J (Appellant) (Respondent) निर्धारर…

THE ANDHRA PRADESH STATE CO-OPERATIVE BANK LTD,VIJAYAWADA vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-5(1), HYDERABAD

In the result, the S.As. filed by the assessee are dismissed

ITA 461/HYD/2023[2012-13]Status: DisposedITAT Hyderabad29 Jul 2024AY 2012-13

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

For Appellant: Shri M.V.Anil Kumar, AdvocateFor Respondent: : Ms. K. Haritha, CIT-DR

Section 36Section 36(1)(vii)Section 36(1)(viia)Section 37

…आयकर अपीलीय अधिकरण, हैदराबाद पीठ IN THE INCOME TAX APPELLATE TRIBUNAL Hyderabad ‘A’ Bench, Hyderabad BEFORE SHRI LALIET KUMAR, JUDICIAL MEMBER AND SHRI MADHUSUDAN SAWDIA, ACCOUNTANT MEMBER आ.अपी.सं /ITA Nos.1796/Hyd/2017,241/Hyd/2018, 464/Hyd/2023 & 460 to 463/Hyd/2023) (निर्धारण वर्ा/Assessment Years(“A.Ys.”): 2008-09 to 2014-15 ) & (S.A. Nos.63,67,64 to 66/Hyd/2023 ) (निर्धारण वर्ा/A.Ys: 2008-09, 2010-11, 2011-12, 2012-13 & 2014-15 ) The Andhra Pradesh State Co- Asst. Commissioner of Income Tax, Vs. Circle 4(1), Hyderabad. operative Bank Limited, Hyderabad. PAN: AAAAT2971J (Appellant) (Respondent) निर्धारर…

THE ANDHRA PRADESH STATE CO-OPERATIVE BANK LTD,VIJAYAWADA vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-4(1), HYDERABAD

In the result, the S.As. filed by the assessee are dismissed

ITA 460/HYD/2023[2011-12]Status: DisposedITAT Hyderabad29 Jul 2024AY 2011-12

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

For Appellant: Shri M.V.Anil Kumar, AdvocateFor Respondent: : Ms. K. Haritha, CIT-DR

Section 36Section 36(1)(vii)Section 36(1)(viia)Section 37

…आयकर अपीलीय अधिकरण, हैदराबाद पीठ IN THE INCOME TAX APPELLATE TRIBUNAL Hyderabad ‘A’ Bench, Hyderabad BEFORE SHRI LALIET KUMAR, JUDICIAL MEMBER AND SHRI MADHUSUDAN SAWDIA, ACCOUNTANT MEMBER आ.अपी.सं /ITA Nos.1796/Hyd/2017,241/Hyd/2018, 464/Hyd/2023 & 460 to 463/Hyd/2023) (निर्धारण वर्ा/Assessment Years(“A.Ys.”): 2008-09 to 2014-15 ) & (S.A. Nos.63,67,64 to 66/Hyd/2023 ) (निर्धारण वर्ा/A.Ys: 2008-09, 2010-11, 2011-12, 2012-13 & 2014-15 ) The Andhra Pradesh State Co- Asst. Commissioner of Income Tax, Vs. Circle 4(1), Hyderabad. operative Bank Limited, Hyderabad. PAN: AAAAT2971J (Appellant) (Respondent) निर्धारर…

THE ANDHRA PRADESH STATE CO OPERATIVE BANK LIMITED,HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-4(1), HYDERABAD

In the result, the S.As. filed by the assessee are dismissed

ITA 241/HYD/2018[2009-10]Status: DisposedITAT Hyderabad29 Jul 2024AY 2009-10

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

For Appellant: Shri M.V.Anil Kumar, AdvocateFor Respondent: : Ms. K. Haritha, CIT-DR

Section 36Section 36(1)(vii)Section 36(1)(viia)Section 37

…आयकर अपीलीय अधिकरण, हैदराबाद पीठ IN THE INCOME TAX APPELLATE TRIBUNAL Hyderabad ‘A’ Bench, Hyderabad BEFORE SHRI LALIET KUMAR, JUDICIAL MEMBER AND SHRI MADHUSUDAN SAWDIA, ACCOUNTANT MEMBER आ.अपी.सं /ITA Nos.1796/Hyd/2017,241/Hyd/2018, 464/Hyd/2023 & 460 to 463/Hyd/2023) (निर्धारण वर्ा/Assessment Years(“A.Ys.”): 2008-09 to 2014-15 ) & (S.A. Nos.63,67,64 to 66/Hyd/2023 ) (निर्धारण वर्ा/A.Ys: 2008-09, 2010-11, 2011-12, 2012-13 & 2014-15 ) The Andhra Pradesh State Co- Asst. Commissioner of Income Tax, Vs. Circle 4(1), Hyderabad. operative Bank Limited, Hyderabad. PAN: AAAAT2971J (Appellant) (Respondent) निर्धारर…

THE ANDHRA PRADESH STATE COOPERATIVE BANK LIMITED,HYDERABAD vs. ASST.COMMISSIONER OF INCOME TAX, CIRCLE-5(1), HYDERABAD

In the result, the S.As. filed by the assessee are dismissed

ITA 1796/HYD/2017[2008-09]Status: DisposedITAT Hyderabad29 Jul 2024AY 2008-09

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

For Appellant: Shri M.V.Anil Kumar, AdvocateFor Respondent: : Ms. K. Haritha, CIT-DR

Section 36Section 36(1)(vii)Section 36(1)(viia)Section 37

…आयकर अपीलीय अधिकरण, हैदराबाद पीठ IN THE INCOME TAX APPELLATE TRIBUNAL Hyderabad ‘A’ Bench, Hyderabad BEFORE SHRI LALIET KUMAR, JUDICIAL MEMBER AND SHRI MADHUSUDAN SAWDIA, ACCOUNTANT MEMBER आ.अपी.सं /ITA Nos.1796/Hyd/2017,241/Hyd/2018, 464/Hyd/2023 & 460 to 463/Hyd/2023) (निर्धारण वर्ा/Assessment Years(“A.Ys.”): 2008-09 to 2014-15 ) & (S.A. Nos.63,67,64 to 66/Hyd/2023 ) (निर्धारण वर्ा/A.Ys: 2008-09, 2010-11, 2011-12, 2012-13 & 2014-15 ) The Andhra Pradesh State Co- Asst. Commissioner of Income Tax, Vs. Circle 4(1), Hyderabad. operative Bank Limited, Hyderabad. PAN: AAAAT2971J (Appellant) (Respondent) निर्धारर…

ADIT (IT) 1(2), MUMBAI vs. CALYON BANK, MUMBAI

ITA 4259/MUM/2014[2007-08]Status: DisposedITAT Mumbai11 Sept 2023AY 2007-08

Bench: Shri Vikas Awasthy& Shri S.Rifaur Rahmanआअसं.9071/मुं/2010 (िन.व. 2006-07) आअसं.3103/मुं/2014 (िन.व. 2007-08) आअसं.1503/मुं/2014 (िन.व. 2008-09) आअसं.1504/मुं/2014 (िन.व. 2009-10) Credit Agricole Corporate & Investment Bank (Formerly Calyon Bank), 11Th Floor, Hoechst House, Nariman Point, Mumbai – 400 021 Pan: Aaccc-3872-B ...... अपीलाथ"/Appellant बनाम Vs. The Asstt. Director Of Income-Tax (International Taxation)-1(2) Mumbai, 1St Floor, Scindia House, Ballard Pier, Mumbai 400 038 ......"ितवादी/Respondent आअसं.4259/मुं/2014 (िन.व. 2007-08) आअसं.1483/मुं/2014 (िन.व. 2008-09) आअसं.1868/मुं/2014 (िन.व. 2009-10) The Asstt. Director Of Income-Tax (International Taxation)-1(2) Mumbai, 1St Floor, Scindia House, Ballard Pier, Mumbai 400 038. ...... अपीलाथ"/Appellant बनाम Vs. Credit Agricole Corporate & Investment Bank (Formerly Calyon Bank), 11Th Floor, Hoechst House

For Appellant: Shri P.J. Pardiwala, Sr.Advocate gwithFor Respondent: Shri Soumendu Kumar Dash, Sr. AR &

…e’s own case for assessment year 2004- 05 dismissed the ground. The Tribunal in assessment year 2003- 04 and 2004- 05 decided the issue against the assessee placing reliance on the decision of Special Bench in the case of Net India Industries Limited vs. ACIT 18 SOT 51. We see no reason to take a different view on parity of facts. Thus, ground no. 4 of appeal is dismissed. Ground No.5: Transfer Pricing Adjustment on interest in respect of call placements and borrowings(Same as ground No.19 in appeal for AY 2006-07); Ground No.6: Taxability in the hands of assessee (Indian Branch) of interest and commission aris…

CREDIT AGRICOLE CORPORATE AND INVESTMENT BANK,MUMBAI vs. ASST DIT (IT) 1(2), MUMBAI

ITA 3103/MUM/2014[2007-08]Status: DisposedITAT Mumbai11 Sept 2023AY 2007-08

Bench: Shri Vikas Awasthy& Shri S.Rifaur Rahmanआअसं.9071/मुं/2010 (िन.व. 2006-07) आअसं.3103/मुं/2014 (िन.व. 2007-08) आअसं.1503/मुं/2014 (िन.व. 2008-09) आअसं.1504/मुं/2014 (िन.व. 2009-10) Credit Agricole Corporate & Investment Bank (Formerly Calyon Bank), 11Th Floor, Hoechst House, Nariman Point, Mumbai – 400 021 Pan: Aaccc-3872-B ...... अपीलाथ"/Appellant बनाम Vs. The Asstt. Director Of Income-Tax (International Taxation)-1(2) Mumbai, 1St Floor, Scindia House, Ballard Pier, Mumbai 400 038 ......"ितवादी/Respondent आअसं.4259/मुं/2014 (िन.व. 2007-08) आअसं.1483/मुं/2014 (िन.व. 2008-09) आअसं.1868/मुं/2014 (िन.व. 2009-10) The Asstt. Director Of Income-Tax (International Taxation)-1(2) Mumbai, 1St Floor, Scindia House, Ballard Pier, Mumbai 400 038. ...... अपीलाथ"/Appellant बनाम Vs. Credit Agricole Corporate & Investment Bank (Formerly Calyon Bank), 11Th Floor, Hoechst House

For Appellant: Shri P.J. Pardiwala, Sr.Advocate gwithFor Respondent: Shri Soumendu Kumar Dash, Sr. AR &

…e’s own case for assessment year 2004- 05 dismissed the ground. The Tribunal in assessment year 2003- 04 and 2004- 05 decided the issue against the assessee placing reliance on the decision of Special Bench in the case of Net India Industries Limited vs. ACIT 18 SOT 51. We see no reason to take a different view on parity of facts. Thus, ground no. 4 of appeal is dismissed. Ground No.5: Transfer Pricing Adjustment on interest in respect of call placements and borrowings(Same as ground No.19 in appeal for AY 2006-07); Ground No.6: Taxability in the hands of assessee (Indian Branch) of interest and commission aris…

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