ADIT CIR 2(2), MUMBAI vs. TAJ TV LTD, MUMBAI
In the result, the appeals of the assessee are allowed and that of the Revenue are dismissed
ITA 2073/MUM/2012[2007-08]Status: DisposedITAT Mumbai23 Dec 2016AY 2007-08
Bench: Sri Amit Shukla,Jm & Sri Ashwani Taneja,Am
Section 143(3)Section 144CSection 195Section 40Section 9Section 9(1)
…the learned CITDR, on the issue of no further attribution of income in the hands of the assessee because the transaction between the assessee and the PE has been found to be at arm‟s length, he relied upon the decision of NGC Network Asia Alc. Vs JCIT [2015] 175 TTJ 403. He has also strongly relied upon the relevant findings of the AO and the directions given by the DRP. 8. With regard to the issue raised in ground No.2 and 3, he has given his brief write-up which is reproduced hereunder:- “1. On the issue whether the Amendments/Explanations inserted in the Income Tax Act can be read into the DTAA or not, in m…