“draft assessment order”

DCIT CC-3(4) Mumbai, Mumbai vs. Essar Ports Limited, Mumbai

Appeal are dismissed, being bereft of merit and devoid of substance

Bench: Shri Amit Shukla, Hon’Ble & Shri Arun Khodpia, Hon’Bledcit Cc 3(4), Mumbai Essar Ports Limited 11, Keshavrao Khadye Marg 613, Kautilya Bhawan G Clock Mahalaxmi Vs Bkc Bandra, Mumbai – 400034 Mumbai – 400051, Maharastra Maharastra

revised return of income of the assessee was not considered by the A.O. As observed hereinabove, the A.O. initially in his draft assessment order passed under Sec. 144C(1) r.w.s. 143(3), dated 18.03.2014, had worked out the disallowance under Sec. 144 r.w.r

Rubicon Research Limited (Formerly Known As Rubicon Research Private Limited), Thane, Maharashtra vs. Deputy Commissioner of Income Tax - Circle 15(3)(1), Mumbai

In the result, assessee’s appeal is allowed for statistical purposes

Bench: Smt. Beena Pillai & Smt. Renu Jauhriआयकर अपील सं./Ita No.6647/Mum/2024 (निर्धारण वर्ा/Assessment Year: 2021-22) Rubicon Research V/S. Deputy Commissioner Of Limited (Formerly बिधम Income Tax- Circle Known As Rubicon 15(3)(1), Mumbai Research Private Aaykar Bhavan, Maharshi Limited) Karve Road, New Marine Medone House, B-75, Lines, Churchgate, Mumbai Road No. 33, Wagle 400020 Estate, Thane 400604. Assessment Unit, National Faceless Assessment Centre Income Tax Department, Ministry Of Finance Delhi स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aabcr1422M Appellant/अपीलधर्थी .. Respondent/प्रनिवधदी निर्ााररती की ओर से /Assessee By: Shri. Darpan Kirpalani रधजस्व की ओर से /Revenue By: Shri. Asif Karmali (Sr Dr)

tested party whereas Ld. TPO rejected the same and applied ‘other method’. 4. Aggrieved with the order of TPO and the draft assessment order issued by the Ld. AO, the assessee filed objections before Ld. DRP, Mumbai. In pursuance to the directions of the DRP, the proposed adjustment

Tfdac Ireland II Limited, Ireland vs. Deputy Commissioner of Income Tax International Tax Circle 4(1)(2) Mumbai, Mumbai

aviation ecosystem, 9 ITA No.1198/Mum/2025 and others professional infrastructure, and strategic location, in line with OECD principles. 9. The AO, however, in the Draft Assessment Order dated 31 March 2024, rejected these submissions and concluded that the Principal Purpose Test (“PPT”) under Articles ... accordingly dismissed as not pressed. Grounds Nos.3 to 3.4 assail the jurisdiction of the ld.DRP in travelling beyond the scope of the draft assessment order, which too has not been argued before us. 16. Thus, on merits, the issues for determination crystallise into the following four: (a) Whether, in view

Dae(Sy22) Leasing (Ireland)41, Designated Activity Company, Mumbai vs. Assistant Commissioner of Income Tax International Taxation Circle 2(1)(2), Mumbai

Bench: SHRI AMIT SHUKLA (Judicial Member), MS PADMAVATHY S (Accountant Member)

Ireland was chosen for well-recognised commercial reasons given its established aviation ecosystem, line with OECD principles. 9. The AO, however, in the Draft Assessment Order dated 31 March 2024, rejected these submissions and concluded that the Principal Purpose Test (“PPT”) under Articles ... accordingly dismissed as not pressed. Grounds Nos. 3 to 3.4 assail the jurisdiction of the ld.DRP in travelling beyond the scope of the draft assessment order, which too has not been argued before us. 16. Thus, on merits, the issues for determination crystallise into the following four: (a) Whether

Dae (Sabs) Leasing Ireland 43 Designated Activity Company, Mumbai vs. Assistant Commissioner of Income Tax Int Tax.Circle 2(1)(2), Mumbai

In the result, appeals of the assessees are allowed and

commercial reasons given its established aviation ecosystem, professional infrastructure, and strategic location, in line with OECD principles. 9. The AO, however, in the Draft Assessment Order dated 31 March 2024, rejected these submissions and concluded that the Principal Purpose Test (“PPT”) under Articles ... accordingly dismissed as not pressed. Grounds Nos.3 to 3.4 assail the jurisdiction of the ld.DRP in travelling beyond the scope of the draft assessment order, which too has not been argued before us. 16. Thus, on merits, the issues for determination crystallise into the following four: (a) Whether, in view

Dae (Sabs) 10296 Ireland Designated Activity Company, Mumbai vs. Assistant Commissioner of Income Tax (Int Taxation), Cirlce 2(1)(2), Mumbai

In the result, appeals of the assessees are allowed and

aviation ecosystem, ITA No.1198/Mum/2025 and others 7 professional infrastructure, and strategic location, in line with OECD principles. 9. The AO, however, in the Draft Assessment Order dated 31 March 2024, rejected these submissions and concluded that the Principal Purpose Test (“PPT”) under Articles ... accordingly dismissed as not pressed. Grounds Nos.3 to 3.4 assail the jurisdiction of the ld.DRP in travelling beyond the scope of the draft assessment order, which too has not been argued before us. 16. Thus, on merits, the issues for determination crystallise into the following four: (a) Whether, in view

Sky High Xliii Leasing Company Limited, Ireland vs. Assistant Commissioner of Income Tax Int Tax Circle 4 (2) (1) Mumbai, Mumbai

aviation ecosystem, 9 ITA No.1198/Mum/2025 and others professional infrastructure, and strategic location, in line with OECD principles. 9. The AO, however, in the Draft Assessment Order dated 31 March 2024, rejected these submissions and concluded that the Principal Purpose Test (“PPT”) under Articles ... accordingly dismissed as not pressed. Grounds Nos.3 to 3.4 assail the jurisdiction of the ld.DRP in travelling beyond the scope of the draft assessment order, which too has not been argued before us. 16. Thus, on merits, the issues for determination crystallise into the following four: (a) Whether, in view

Ortus Aircraft Lease 5( Dublin) Limited, Mumbai vs. Deputy Commissioner of Income Tax Circle 3(2)(2) International Taxation, Mumbai

commercial reasons given its established aviation ecosystem, professional infrastructure, and strategic location, in line with OECD principles. 9. The AO, however, in the Draft Assessment Order dated 31 March 2024, rejected these submissions and concluded that the Principal Purpose Test (“PPT”) under Articles ... accordingly dismissed as not pressed. Grounds Nos.3 to 3.4 assail the jurisdiction of the ld.DRP in travelling beyond the scope of the draft assessment order, which too has not been argued before us. 16. Thus, on merits, the issues for determination crystallise into the following four: (a) Whether, in view

Sunflower Aircraft Leasing Limited, Mumbai vs. Assistant Commissioner of Income Tax Circle 4(2)(2) International Tax, Mumbai

In the result, the appeal of the assessee stands allowed

international flights since September 2011, and the leases did not contain any restriction on redeploying the aircraft for international traffic. 6. In the draft assessment order dated 31 March 2024, the AO denied the assessee's claim to treaty protection. He invoked the Principal Purpose Test (“PPT”) as enshrined ... under:- "Panel notes that the Ld. AO has not been able to make a case for application of Principal Purpose Test in the Draft Assessment Order, or in the enquiry report dated 19.12.2024. Hence, Ground of Objection No. 5 and 6 of the applicant are accepted by the Panel

Ortus Aircraft Lease 6(Dublin) Limited, Mumbai vs. Deputy Commissioner of Income Tax Circle 3(2)(2) International Taxation, Mumbai

Bench: SHRI AMIT SHUKLA (Judicial Member), MS PADMAVATHY S (Accountant Member)

Ireland was chosen for well-recognised commercial reasons given its established aviation ecosystem, line with OECD principles. 9. The AO, however, in the Draft Assessment Order dated 31 March 2024, rejected these submissions and concluded that the Principal Purpose Test (“PPT”) under Articles ... accordingly dismissed as not pressed. Grounds Nos. 3 to 3.4 assail the jurisdiction of the ld.DRP in travelling beyond the scope of the draft assessment order, which too has not been argued before us. 16. Thus, on merits, the issues for determination crystallise into the following four: (a) Whether