Steria (India) Ltd. v. CIT

386 ITR 390High Court2016#1390 most cited

What is Steria (India) Ltd. v. CIT authority for?

Managerial services are not considered 'fees for included services' under Article 13(4) of the India-UK Double Taxation Avoidance Agreement, thus payments for such services are not taxable as FTS under the treaty.

83

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

Steria (India) Ltd. v. CIT · managerial services · fees for included services · FTS · India-UK DTAA · Article 13(4) · Section 9(1)(vii) · Section 195 · non-resident taxation · make available condition · DTAA interpretation

Also reported as

72 Taxmann.com 1194 ITD 729241 Taxmann 268

Sections most often in play

Section 1961Section 143(3)Section 144C(13)Section 234BSection 115ASection 234DSection 9(1)(vii)Section 195

Issues it is cited on

make available conditionsection 44bbbsection 35ddamake available clauseuse of equipmentsection 35ddsection 92c(1)dependent agent pesection 90(1)construction pefees for included servicessection 44bb

Judgments citing Steria (India) Ltd. v. CIT

UK GRID SOLUTIONS LIMITED,STAFFORD, UNITED KINGDOM vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE INT TAX 3(1)(1)DEL, DELHI

In the result, appeal of the assessee is allowed in terms aforesaid

ITA 2042/DEL/2025[2022-23]Status: DisposedITAT Delhi10 Nov 2025AY 2022-23

Bench: Shri Vikas Awasthy & Shri Brajesh Kumar Singh[Assessment Year: 2022-23] Uk Grid Solutions Limited, The Deputy Commissioner Of Income St Leonards Building, Harry Tax, Circle International Taxation Kerr Dive, Stafford St16 1Wt, Vs -3(1)(1), Civic Centre, Minto Road United Kingdom-99999 New Delhi-110002 Pan-Aaica6271A Assessee/Appellant Revenue/Respondent

Section 143(3)Section 44BSection 9(1)(vii)

…Bio Rad Laboratories Incvs ACIT: ITA No.994 & 996/Del/2022 dated 30.12.2022 (Del Trib). 34.1 Supporting his contention that Managerial services are not FTS in absence of ‘managerial’ word in India-UK DTAA the ld. Sr. Counsel relied Steria (India) Ltd vs CIT: 386 ITR 390 (Del) and Everest Global Incvs DDIT: 194 ITD 729 (Del Trib.). Ld. DR however, defended the findings. 35. In this context, it can be observed that the Global Operation Fees Agreement made available at page no. 372-396 of paper book along with copy of invoices available at page no. 397-403 of the paper book establish, that the assessee had agreed t…

M/S. CEVA FREIGHT LLC,NEW DELHI vs. DDIT, NEW DELHI

In the result, the appeal of the assessee in ITA No

ITA 1264/DEL/2014[2010-11]Status: DisposedITAT Delhi18 Jul 2025AY 2010-11

Bench: Ms. Madhumita Roy & Shri Naveen Chandra

For Appellant: Shri Salil Kapoor, AdvFor Respondent: Shri Vizay B. Vasanta, CIT-DR
Section 143(2)Section 143(3)Section 234B

…ding that services have been rendered. The support services like Information system, legal services, accounting services etc. is in the nature of Managerial services. Reliance is placed on the Hon'ble Delhi High Court ruling in the case of Steria India Ltd. 386 ITR 390 [Delhi] wherein, the Court accepts the same view in the para 3 of its order and held in para 19 that fees for included services in Article 13(4) of the Indo-UK DTAA clearly excludes managerial services. Once the expression managerial services is out the taxability under the treaty does not arises. 13. The ld. counsel for the assessee further…

DEPUTY COMMISSIONER OF INCOME TAX, GURGAON vs. HAYS BUSINESS SOLUTIONS PRIVATE LIMITED, GURGAON

The appeal of the Revenue is dismissed

ITA 3003/DEL/2023[2014-15]Status: DisposedITAT Delhi29 May 2025AY 2014-15

Bench: SHRI MAHAVIR SINGH (Vice President), SHRI MANISH AGARWAL (Accountant Member)

Section 143(2)Section 143(3)Section 195(1)Section 250Section 37Section 40

…s and thus these managerial services are not covered within the ambit of FTS as defined under Article 13 of India UK Tax Treaty.  Reliance in this regard is placed on the ruling of the Hon'ble Delhi High Court in the case of Steria (India) Ltd. v. CIT (2016) 386 ITR 390 wherein the HC has held DCIT vs. Hays Business Solutions Pvt. Ltd. that the services rendered by the non-resident to the assessee were managerial services which is outside the ambit of FTS occurring in article 13(4) of the India UK tax treaty. Therefore, the question of the assessee having to deduct tax at source from payments for the managerial…

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)

Section 143(3)

…Mitsui Banking Corporation vs. DDIT. 136 ITD 66 (Mum-SB). This is a recurring issue in assessee's case. In Assessment Year 2005-06 similar issue had come up, the Tribunal placing reliance on the decision of Hon'ble High Court in the case of Steria India Ltd., 386 ITR 390 dismissed the ground raised in appeal by the Revenue. 18.1 Both sides heard. We find that identical issue has been decided by the Co-ordinate Bench in an appeal by the Revenue in ITA No.6682/Mum/2012 for Assessment Year 2005-06 vide order dated 05/01/2018. The assessee has placed reliance on the decision in the case of Sumitomo Mitsui Banking Cor…

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)

Section 143(3)

…Mitsui Banking Corporation vs. DDIT. 136 ITD 66 (Mum-SB). This is a recurring issue in assessee's case. In Assessment Year 2005-06 similar issue had come up, the Tribunal placing reliance on the decision of Hon'ble High Court in the case of Steria India Ltd., 386 ITR 390 dismissed the ground raised in appeal by the Revenue. 18.1 Both sides heard. We find that identical issue has been decided by the Co-ordinate Bench in an appeal by the Revenue in ITA No.6682/Mum/2012 for Assessment Year 2005-06 vide order dated 05/01/2018. The assessee has placed reliance on the decision in the case of Sumitomo Mitsui Banking Cor…

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)

Section 143(3)

…Mitsui Banking Corporation vs. DDIT. 136 ITD 66 (Mum-SB). This is a recurring issue in assessee's case. In Assessment Year 2005-06 similar issue had come up, the Tribunal placing reliance on the decision of Hon'ble High Court in the case of Steria India Ltd., 386 ITR 390 dismissed the ground raised in appeal by the Revenue. 18.1 Both sides heard. We find that identical issue has been decided by the Co-ordinate Bench in an appeal by the Revenue in ITA No.6682/Mum/2012 for Assessment Year 2005-06 vide order dated 05/01/2018. The assessee has placed reliance on the decision in the case of Sumitomo Mitsui Banking Cor…

SUBODH GUPTA,DELHI vs. ACIT, NEW DELHI

In the result, the appeal of the assessee in ITA No

ITA 1264/DEL/2017[2009-10]Status: DisposedITAT Delhi31 Jan 2025AY 2009-10

Bench: Ms. Madhumita Roy & Shri Naveen Chandra

For Appellant: Shri Salil Kapoor, AdvFor Respondent: Shri Vizay B. Vasanta, CIT-DR
Section 143(2)Section 143(3)Section 234B

…ding that services have been rendered. The support services like Information system, legal services, accounting services etc. is in the nature of Managerial services. Reliance is placed on the Hon'ble Delhi High Court ruling in the case of Steria India Ltd. 386 ITR 390 [Delhi] wherein, the Court accepts the same view in the para 3 of its order and held in para 19 that fees for included services in Article 13(4) of the Indo-UK DTAA clearly excludes managerial services. Once the expression managerial services is out the taxability under the treaty does not arises. 13. The ld. counsel for the assessee further…

LLOYD'S REGISTER ASIA (INDIA BRANCH OFFICE),MUMBAI vs. DCIT (INTERNATIONAL TAXATION)-3(1)(2), MUMBAI

In the result, all these appeals filed by the assessee are allowed for statistical

ITA 878/MUM/2024[2011-12]Status: DisposedITAT Mumbai29 Aug 2024AY 2011-12

Bench: Ms. Kavitha Rajagopal, Jm & Ms. Renu Jauhri, Am

For Appellant: Shri Nitesh JoshiFor Respondent: Shri Anil Sant-Addl.CIT DR
Section 250

…IN THE INCOME TAX APPELLATE TRIBUNAL “I” BENCH, MUMBAI BEFORE MS. KAVITHA RAJAGOPAL, JM AND MS. RENU JAUHRI, AM ITA No. 1778/Mum/2024 (Assessment Year: 2016-17) ITA No. 1780/Mum/2024 (Assessment Year: 2013-14) Dy. CIT(IT)-3(1)(2) Lloyds Register of Shipping Room No.1628, Room No.1628,16th Floor, Air India Vs. 16th Floor, Air India Building, Building, Nariman Point, Nariman Point, Mumbai-400021 Mumbai-400021 PAN/GIR No. AAACL 2209 B (Revenue) : (Assessee) ITA No.1776 /Mum/2024 (Assessment Year: 2016-17) Dy. CIT (IT) -3(1)(2) Lloyd’s Register Asia 16th Floor, Air India Building, Nariman (India Brand Office) 17th…

DEPUTY COMMISSIONER OF INCOME TAX(IT)-3(1)(2), MUMBAI, MUMBAI vs. LLOYDS REGISTER OF SHIPPING, MUMBAI

In the result, all these appeals filed by the assessee are allowed for statistical

ITA 1777/MUM/2024[2021-22]Status: DisposedITAT Mumbai29 Aug 2024AY 2021-22

Bench: Ms. Kavitha Rajagopal, Jm & Ms. Renu Jauhri, Am

For Appellant: Shri Nitesh JoshiFor Respondent: Shri Anil Sant-Addl.CIT DR
Section 250

…IN THE INCOME TAX APPELLATE TRIBUNAL “I” BENCH, MUMBAI BEFORE MS. KAVITHA RAJAGOPAL, JM AND MS. RENU JAUHRI, AM ITA No. 1778/Mum/2024 (Assessment Year: 2016-17) ITA No. 1780/Mum/2024 (Assessment Year: 2013-14) Dy. CIT(IT)-3(1)(2) Lloyds Register of Shipping Room No.1628, Room No.1628,16th Floor, Air India Vs. 16th Floor, Air India Building, Building, Nariman Point, Nariman Point, Mumbai-400021 Mumbai-400021 PAN/GIR No. AAACL 2209 B (Revenue) : (Assessee) ITA No.1776 /Mum/2024 (Assessment Year: 2016-17) Dy. CIT (IT) -3(1)(2) Lloyd’s Register Asia 16th Floor, Air India Building, Nariman (India Brand Office) 17th…

DEPUTY COMMISSIONER OF INCOME TAX(IT)-3(1)(2), MUMBAI, MUMBAI vs. LLOYDS REGISTER ASIA, MUMBAI

In the result, all these appeals filed by the assessee are allowed for statistical

ITA 1776/MUM/2024[2016-17]Status: DisposedITAT Mumbai29 Aug 2024AY 2016-17

Bench: Ms. Kavitha Rajagopal, Jm & Ms. Renu Jauhri, Am

For Appellant: Shri Nitesh JoshiFor Respondent: Shri Anil Sant-Addl.CIT DR
Section 250

…IN THE INCOME TAX APPELLATE TRIBUNAL “I” BENCH, MUMBAI BEFORE MS. KAVITHA RAJAGOPAL, JM AND MS. RENU JAUHRI, AM ITA No. 1778/Mum/2024 (Assessment Year: 2016-17) ITA No. 1780/Mum/2024 (Assessment Year: 2013-14) Dy. CIT(IT)-3(1)(2) Lloyds Register of Shipping Room No.1628, Room No.1628,16th Floor, Air India Vs. 16th Floor, Air India Building, Building, Nariman Point, Nariman Point, Mumbai-400021 Mumbai-400021 PAN/GIR No. AAACL 2209 B (Revenue) : (Assessee) ITA No.1776 /Mum/2024 (Assessment Year: 2016-17) Dy. CIT (IT) -3(1)(2) Lloyd’s Register Asia 16th Floor, Air India Building, Nariman (India Brand Office) 17th…

LIOYD'S REGISTER ASIA (INDIA BRANCH OFFICE),MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION -3(1)(2) , MUMBAI

In the result, all these appeals filed by the assessee are allowed for statistical

ITA 1455/MUM/2024[2016-17]Status: DisposedITAT Mumbai29 Aug 2024AY 2016-17

Bench: Ms. Kavitha Rajagopal, Jm & Ms. Renu Jauhri, Am

For Appellant: Shri Nitesh JoshiFor Respondent: Shri Anil Sant-Addl.CIT DR
Section 250

…IN THE INCOME TAX APPELLATE TRIBUNAL “I” BENCH, MUMBAI BEFORE MS. KAVITHA RAJAGOPAL, JM AND MS. RENU JAUHRI, AM ITA No. 1778/Mum/2024 (Assessment Year: 2016-17) ITA No. 1780/Mum/2024 (Assessment Year: 2013-14) Dy. CIT(IT)-3(1)(2) Lloyds Register of Shipping Room No.1628, Room No.1628,16th Floor, Air India Vs. 16th Floor, Air India Building, Building, Nariman Point, Nariman Point, Mumbai-400021 Mumbai-400021 PAN/GIR No. AAACL 2209 B (Revenue) : (Assessee) ITA No.1776 /Mum/2024 (Assessment Year: 2016-17) Dy. CIT (IT) -3(1)(2) Lloyd’s Register Asia 16th Floor, Air India Building, Nariman (India Brand Office) 17th…

EMERGING MARKETS EQUITY INDEX MASTER FUND,MUMBAI vs. DCIT (INTERNATIONAL TAXATION)- 2(2)(1), MUMBAI

In the result, all these appeals filed by the assessee are allowed for statistical

ITA 4588/MUM/2023[2021-22]Status: DisposedITAT Mumbai29 Aug 2024AY 2021-22

Bench: Ms. Kavitha Rajagopal, Jm & Ms. Renu Jauhri, Am

For Appellant: Shri Nitesh JoshiFor Respondent: Shri Anil Sant-Addl.CIT DR
Section 250

…IN THE INCOME TAX APPELLATE TRIBUNAL “I” BENCH, MUMBAI BEFORE MS. KAVITHA RAJAGOPAL, JM AND MS. RENU JAUHRI, AM ITA No. 1778/Mum/2024 (Assessment Year: 2016-17) ITA No. 1780/Mum/2024 (Assessment Year: 2013-14) Dy. CIT(IT)-3(1)(2) Lloyds Register of Shipping Room No.1628, Room No.1628,16th Floor, Air India Vs. 16th Floor, Air India Building, Building, Nariman Point, Nariman Point, Mumbai-400021 Mumbai-400021 PAN/GIR No. AAACL 2209 B (Revenue) : (Assessee) ITA No.1776 /Mum/2024 (Assessment Year: 2016-17) Dy. CIT (IT) -3(1)(2) Lloyd’s Register Asia 16th Floor, Air India Building, Nariman (India Brand Office) 17th…

JCDECAUX S.A.,NEW DELHI vs. ACIT, CIRCLE-2(1)(2), INTERNATIONAL TAXATION, NEW DELHI

In the result, the appeal of the assessee is party allowed

ITA 2473/DEL/2022[2018-19]Status: DisposedITAT Delhi03 May 2024AY 2018-19

Bench: Dr. B. R. R. Kumarms. Astha Chandra

For Appellant: Sh. K. M. Gupta, Adv. &For Respondent: Sh. Om Parkash, Sr. DR
Section 143(3)Section 234BSection 270ASection 9(1)(vii)

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘D’, NEW DELHI Before Dr. B. R. R. Kumar, Accountant Member Ms. Astha Chandra, Judicial Member ITA No. 2473/Del/2022 : Asstt. Year: 2018-19 JCDECAUX S.A, Vs ACIT, C/o. JCDecaux Advertising India P Circle 2(1)(2), Ltd., Plot No. 153, 3rd Floor, Okhla New Delhi Industrial Estate, Phase-III, New Delhi 110020 (APPELLANT) (RESPONDENT) PAN No. AACCJ 8567 A Assessee by : Sh. K. M. Gupta, Adv. & Ms. Saloni Shital, AR Revenue by : Sh. Om Parkash, Sr. DR Date of Hearing: 12.04.2024 Date of Pronouncement: 03.05.2024 ORDER Per Dr. B. R. R. Kumar, Accountant Member: The prese…

UK GRID SOLUTIONS LIMITED,UNITED KINGDOM vs. DCIT CIRCLE INTERNATIONAL TAX 3(1)(1), NEW DELHI

In the result, the appeal of the assessee in ITA No

ITA 885/DEL/2023[2017-18]Status: DisposedITAT Delhi13 Mar 2024AY 2017-18

Bench: Shri C. N. Prasad & Shri M. Balaganesh

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Vizay B. Vasanta, CIT DR
Section 143(3)Section 144C(13)

…Bio Rad Laboratories Incvs ACIT: ITA No.994 & 996/Del/2022 dated 30.12.2022 (Del Trib)Ld. 34.1 Supporting his contention that Managerial services are not FTS in absence of 'managerial word in India-UK DTAA the Id. Sr. Counsel relied Steria (India) Ltd vs CIT: 386 ITR 390 (Del) and Everest Global Incvs DDIT: 194 ITD 729 (Del Trib.). Ld. DR however, defended the findings. 35. In this context, it can be observed that the Global Operation Fees Agreement made available at page no. 372-396 of paper book along with copy of invoices available at page no. 397-403 of the paper book establish, that the assessee had agreed t…

UK GRID SOLUTIONS LIMITED,UNITED KINGDOM vs. DCIT CIRCLE INTERNATIONAL TAX 3(1)(1), NEW DELHI

In the result, the appeal of the assessee in ITA No

ITA 884/DEL/2023[2016-17]Status: DisposedITAT Delhi13 Mar 2024AY 2016-17

Bench: Shri C. N. Prasad & Shri M. Balaganesh

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Vizay B. Vasanta, CIT DR
Section 143(3)Section 144C(13)

…Bio Rad Laboratories Incvs ACIT: ITA No.994 & 996/Del/2022 dated 30.12.2022 (Del Trib)Ld. 34.1 Supporting his contention that Managerial services are not FTS in absence of 'managerial word in India-UK DTAA the Id. Sr. Counsel relied Steria (India) Ltd vs CIT: 386 ITR 390 (Del) and Everest Global Incvs DDIT: 194 ITD 729 (Del Trib.). Ld. DR however, defended the findings. 35. In this context, it can be observed that the Global Operation Fees Agreement made available at page no. 372-396 of paper book along with copy of invoices available at page no. 397-403 of the paper book establish, that the assessee had agreed t…

UK GRID SOLUTIONS LIMITED ,UNITED KINGDOM vs. DCIT CIRCLE INTL. TAXATION 3(1)(1), NEW DELHI

In the result, the appeal of the assessee in ITA No

ITA 2240/DEL/2023[2020-21]Status: DisposedITAT Delhi13 Mar 2024AY 2020-21

Bench: Shri C. N. Prasad & Shri M. Balaganesh

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Vizay B. Vasanta, CIT DR
Section 143(3)Section 144C(13)

…Bio Rad Laboratories Incvs ACIT: ITA No.994 & 996/Del/2022 dated 30.12.2022 (Del Trib)Ld. 34.1 Supporting his contention that Managerial services are not FTS in absence of 'managerial word in India-UK DTAA the Id. Sr. Counsel relied Steria (India) Ltd vs CIT: 386 ITR 390 (Del) and Everest Global Incvs DDIT: 194 ITD 729 (Del Trib.). Ld. DR however, defended the findings. 35. In this context, it can be observed that the Global Operation Fees Agreement made available at page no. 372-396 of paper book along with copy of invoices available at page no. 397-403 of the paper book establish, that the assessee had agreed t…

UK GRID SOLUTIONS LIMITED ,UNITED KINGDOM vs. DCIT CIRCLE INTL. TAXATION 3(1)(1), NEW DELHI

In the result, the appeal of the assessee in ITA No

ITA 2239/DEL/2023[2015-16]Status: DisposedITAT Delhi13 Mar 2024AY 2015-16

Bench: Shri C. N. Prasad & Shri M. Balaganesh

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Vizay B. Vasanta, CIT DR
Section 143(3)Section 144C(13)

…Bio Rad Laboratories Incvs ACIT: ITA No.994 & 996/Del/2022 dated 30.12.2022 (Del Trib)Ld. 34.1 Supporting his contention that Managerial services are not FTS in absence of 'managerial word in India-UK DTAA the Id. Sr. Counsel relied Steria (India) Ltd vs CIT: 386 ITR 390 (Del) and Everest Global Incvs DDIT: 194 ITD 729 (Del Trib.). Ld. DR however, defended the findings. 35. In this context, it can be observed that the Global Operation Fees Agreement made available at page no. 372-396 of paper book along with copy of invoices available at page no. 397-403 of the paper book establish, that the assessee had agreed t…

DCIT, CIRCLE-3(3)(1), MUMBAI vs. M/S. TOTAL ENERGIES MARKETING INDIA P LTD (FORMERLY KNOWN AS M/S. TOTAL OIL INDIA P LTD, MUMBAI

ITA 97/MUM/2023[2017-18]Status: DisposedITAT Mumbai03 Nov 2023AY 2017-18

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm

For Appellant: Shri Ketan VedFor Respondent: Shri Biswanath Das, D.R
Section 115Section 143(3)Section 40

…IN THE INCOME TAX APPELLATE TRIBUNAL “E” BENCH, MUMBAI BEFORE SHRI PRASHANT MAHARISHI, AM AND SHRI SANDEEP SINGH KARHAIL, JM ITA No.97 & 96/MUM/2023 Assessment Year: 2017-18 AND 2018-19 DCIT, Circle 3(3)(1) v. M/s Total Energies Marketing Mumbai India Pvt. Ltd. (Formerly Known as M/s Total Oil India Pvt. Ltd.) 3rd Floor, The Leela Galleria, Andheri, Kurla Road, Andheri (East), Mumbai (Appellant) (Respondent) CO No. 30 & 29/MUM/2023 [In ITA No.97 & 96/MUM/2023] Assessment Year: 2017-18 AND 2018-19 M/s Total Energies Marketing India v. DCIT, Circle 3(3)(1) Pvt. Ltd. Mumbai (Formerly Known as M/s Total Oil India Pvt…

DCIT, CIRCLE-3(3)(1), MUMBAI vs. M/S. TOTAL ENERGIES MARKETING INDIA P LTD. (FORMERLY KNOWN AS M/S. TOTAL OIL INDIA P LTD.), MUMBAI

ITA 96/MUM/2023[2018-19]Status: DisposedITAT Mumbai03 Nov 2023AY 2018-19

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm

For Appellant: Shri Ketan VedFor Respondent: Shri Biswanath Das, D.R
Section 115Section 143(3)Section 40

…IN THE INCOME TAX APPELLATE TRIBUNAL “E” BENCH, MUMBAI BEFORE SHRI PRASHANT MAHARISHI, AM AND SHRI SANDEEP SINGH KARHAIL, JM ITA No.97 & 96/MUM/2023 Assessment Year: 2017-18 AND 2018-19 DCIT, Circle 3(3)(1) v. M/s Total Energies Marketing Mumbai India Pvt. Ltd. (Formerly Known as M/s Total Oil India Pvt. Ltd.) 3rd Floor, The Leela Galleria, Andheri, Kurla Road, Andheri (East), Mumbai (Appellant) (Respondent) CO No. 30 & 29/MUM/2023 [In ITA No.97 & 96/MUM/2023] Assessment Year: 2017-18 AND 2018-19 M/s Total Energies Marketing India v. DCIT, Circle 3(3)(1) Pvt. Ltd. Mumbai (Formerly Known as M/s Total Oil India Pvt…

LEGRAND NEDERLAND B.V.,MUMBAI vs. ASSTT. COMM. OF INCOME TAX 3(1)(2), MUMBAI

In the result, appeal filed by the assessee is partly allowed

ITA 2487/MUM/2022[2017-18]Status: DisposedITAT Mumbai13 Oct 2023AY 2017-18

Bench: Shri Aby T. Varkey, Hon'Ble & Shri S. Rifaur Rahman, Hon'Blelegrand Nederland B.V. V. Acit (Intl. Taxation) – 3(1)(2) 16Th Floor, Air India Building 61/62, 6Th Floor Nariman Point, Mumbai Kalpatru Square, Kondivita Road Off. Andheri Road, Andheri (E) Mumbai - 400059 Pan: Aaccl1156B (Appellant) (Respondent) Assessee Represented By : Shri P.J. Pardiwala & Shri Prayas Jain Department Represented By : Shri Amit Kumar Soni

Section 10(34)Section 112(1)(c)Section 115Section 144C(5)Section 2(22)(d)Section 244ASection 270A

…le. It is not necessary to issue a separate notification to make the protocol effective. In this regard, reliance is placed, in addition of the aforementioned judgements, on the judgement of Hon'ble Delhi High Court in case of Steria (India) Ltd. v.CIT [2016] 386 ITR 390 (Delhi) and Pune ITAT in case of GRI Renewable Industries S.L. v. ACIT (IT) [20221 100 ITRCT) 470 (Pune-Trib.)] 29. In view of the above, Ld. AR of the assessee submitted that if at all the alleged dividend is taxed in the hands of the assessee (which it is not taxable at all), the tax rate on dividend should not exceed 5% as per the MFN Clause…

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