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“dependent agent PE”

International TaxDTAA Article 5DTAA Article 5172 judgments

The decision most relied on for dependent agent PE is DIT v. Morgan Stanley & Co. (292 ITR 416), cited in 360 judgments on BharatTax.

Leading authorities on dependent agent PE

DIT v. Morgan Stanley & Co.
292 ITR 416 · 2007 · Supreme Court
360
citing judgments

A Permanent Establishment (PE) signifies a foreign enterprise's virtual projection into another country, with a fixed place PE existing where an MNE's business is wholly or partly carried on. A dependent agent PE requires the agent to act as such and/or have the authority to conclude contracts for the foreign enterprise under DTAA provisions.

Motorola Inc. v. Dy. CIT
95 ITD 269 · 2005 · High Court
213
citing judgments

Revenue must demonstrate the existence of a Permanent Establishment (PE) of a foreign enterprise in India, including establishing that transactions underlying a Dependent Agent PE were not at arm's length. Income from the sale of goods is not taxable in India if title and risk in the goods pass outside India.

National Petroleum Construction Company v. DIT
383 ITR 648 · 2016 · High Court
69
citing judgments

An Indian agent providing marketing services, without the authority to conclude contracts on behalf of a foreign company, does not constitute a Dependent Agent Permanent Establishment (DAPE) for the foreign company in India under DTAA provisions.

DIT v. E-Funds IT Solution
364 ITR 256 · 2014 · High Court
61
citing judgments

A subsidiary is an independent legal entity, and the mere relationship of holding-subsidiary or control by itself does not result in a Permanent Establishment (PE) for the foreign company in India, whether it be a fixed place PE or a dependent agent PE, even when the subsidiary provides outsourced services.

Delmas France v. Asstt. DIT (IT)
17 Taxmann.com 91 · 2012 · ITAT
49
citing judgments

The ITAT evaluates the profit neutrality theory for a Dependent Agent Permanent Establishment (DAPE), stating that unlike a service PE, a DAPE assumes entrepreneurship risk which must be considered for arm's length remuneration.

DIT v. Galileo International Inc.
224 CTR 251 · High Court
37
citing judgments

If the income attributable to a Permanent Establishment (PE) in India is less than the remuneration paid to a dependent agent, the assessment is extinguished and no further computation of income is required.

Galileo International Inc. v. DCIT
19 SOT 257 · 2008 · ITAT
31
citing judgments

A Computer Reservation System (CRS) installed at the premises of Indian subscribers can constitute a Permanent Establishment (PE) in India, and a portion of income from Indian operations may be taxable in India, potentially exhausted by commission paid to Indian distributors.

Western Union Financial Services Inc. v. ADIT
104 ITD 34 · 2007 · ITAT
26
citing judgments

Software installed in India granting access to an assessee's mainframe located outside India does not constitute a Permanent Establishment (PE) in India. Agents are not considered to have an agency PE if they are not economically dependent on the assessee and lack the authority to conclude contracts.

Judgments citing dependent agent PE

Adobe Systems Software Ireland Limited, Dublin (Ireland) vs. ACIT Circle 1(1)(1), International Taxation, New Delhi

Accordingly, the additions made by the Ld. AO in the impugned case deserve to be deleted on the merit for the year under consideration. Thus, the grounds raised are allowed and appeal of asseessee ...

ITA 3672/DEL/2023[AY 2021-22]Status: DisposedITAT Delhi09 Feb 2024

Bench: Shri G.S. Pannu, Hon’Ble & Shri Anubhav Sharmastay Application No.52/Del/2024 (Ita No.3672/Del/2023) Assessment Year: 2021-22 & Assessment Year: 2021-22 Adobe Systems Software Ireland Vs Acit, Limited, Circle-1(1)(1), Dublin (Ireland), International Taxation, 4-6, Riverwalk, Citywest Business New Delhi. Campus, Saggart, Dublin 24, Ireland. Pan: Aahca7203M (Applicant) (Respondent) Assessee By : Shri Ravi Sharma, Advocate & Ms Shruti Khimta, Ar Revenue By : Shri Om Parkash, Sr. Dr Date Of Hearing : 09.02.2024 Date Of Pronouncement : 09.02.2024 Order Per Anubhav Sharma, Jm: Heard & Perused The Records. 2. The Stay Application In Hand Has Been Filed For The Stay Of Demand In Regard To Ay 2021-22 And, During The Course Of Argument, It Was Submitted By Ita No.52/Del/2024

For Appellant: Shri Ravi Sharma, Advocate &For Respondent: Shri Om Parkash, Sr. DR
Section 139(1)

held that even as per the provisions of the India-Ireland tax treaty, the Appellant has a dependent agent PE in India in the form of Adobe India and that the premises of Adobe India also form a fixed place PE for the Appellant in India. In view ... assessee and its AE in India has been found to be at arm’s length, whether further profit can be attributed to the dependent agent PE in India, if at all, such a PE exists in India. In the facts of the present appeal, in assessment year 2018-19, though

Sabre Glbl Inc., New Delhi vs. ACIT (International Taxation), Circle- 3(1)(2), New Delhi

In the result, all the appeals of the assessee are allowed and that of the Revenue stands dismissed

ITA 6040/DEL/2019[2016-17]Status: HeardITAT Delhi09 Feb 2024AY 2016-17

Bench: Sh. G.S.Pannu, Hon’Ble & Sh. Anubhav Sharmaita No. 216/Del/2016, A.Y. 2012-13 Ita No. 559/Del/2017, A.Y. 2013-14 Ita No. 4838/Del/2017, A.Y. 2014-15 Ita No. 7724/Del/2018, A.Y. 2015-16 Ita No. 6040/Del/2019, A.Y. 2016-17 Sabre Glbl Inc. Vs. Asstt. Commissioner Of Income Mr. Tarandeep Singh, Tax, Adv. Circle-3(1)(2), C/O. Ms Associates, International Tax F-99, Lajpat Nagar-Ii, New Delhi New Delhi Pan : Aaact7216Q (Appellant) (Respondent) Deputy Commissioner Of Vs. Sabre Glbl Inc. Income Tax, Mr. Tarandeep Singh, Adv. International Taxation, C/O. Ms Associates, New Delhi F-99, Lajpat Nagar-Ii, New Delhi-110024 Pan : Aaact7216Q (Appellant) (Respondent) Assessee By Sh. Tarandeep Singh, Adv. Revenue By Sh. Vizay B. Vasanta, Cit-Dr

Section 143(2)Section 143(3)Section 144C(1)

above, the assessee shall be deemed to have a permanent establishment in India.” 28.6 The Tribunal next examined the question of existence of dependent agent PE and made following observations in para 17.3 and 17.4 ; “17.3 The next question arises is whether the assesee has a PE in India

Sabre Glbl Inc., New Delhi vs. ACIT (International Taxation), Circle- 3(1)(2), New Delhi

In the result, all the appeals of the assessee are allowed and that of the Revenue stands dismissed

ITA 7724/DEL/2018[2015-16]Status: HeardITAT Delhi09 Feb 2024AY 2015-16

Bench: Sh. G.S.Pannu, Hon’Ble & Sh. Anubhav Sharmaita No. 216/Del/2016, A.Y. 2012-13 Ita No. 559/Del/2017, A.Y. 2013-14 Ita No. 4838/Del/2017, A.Y. 2014-15 Ita No. 7724/Del/2018, A.Y. 2015-16 Ita No. 6040/Del/2019, A.Y. 2016-17 Sabre Glbl Inc. Vs. Asstt. Commissioner Of Income Mr. Tarandeep Singh, Tax, Adv. Circle-3(1)(2), C/O. Ms Associates, International Tax F-99, Lajpat Nagar-Ii, New Delhi New Delhi Pan : Aaact7216Q (Appellant) (Respondent) Deputy Commissioner Of Vs. Sabre Glbl Inc. Income Tax, Mr. Tarandeep Singh, Adv. International Taxation, C/O. Ms Associates, New Delhi F-99, Lajpat Nagar-Ii, New Delhi-110024 Pan : Aaact7216Q (Appellant) (Respondent) Assessee By Sh. Tarandeep Singh, Adv. Revenue By Sh. Vizay B. Vasanta, Cit-Dr

Section 143(2)Section 143(3)Section 144C(1)

above, the assessee shall be deemed to have a permanent establishment in India.” 28.6 The Tribunal next examined the question of existence of dependent agent PE and made following observations in para 17.3 and 17.4 ; “17.3 The next question arises is whether the assesee has a PE in India

Sabre Glbl Inc., New Delhi vs. DCIT (International Taxation), New Delhi

In the result, all the appeals of the assessee are allowed and that of the Revenue stands dismissed

ITA 559/DEL/2017[2013-14]Status: HeardITAT Delhi09 Feb 2024AY 2013-14

Bench: Sh. G.S.Pannu, Hon’Ble & Sh. Anubhav Sharmaita No. 216/Del/2016, A.Y. 2012-13 Ita No. 559/Del/2017, A.Y. 2013-14 Ita No. 4838/Del/2017, A.Y. 2014-15 Ita No. 7724/Del/2018, A.Y. 2015-16 Ita No. 6040/Del/2019, A.Y. 2016-17 Sabre Glbl Inc. Vs. Asstt. Commissioner Of Income Mr. Tarandeep Singh, Tax, Adv. Circle-3(1)(2), C/O. Ms Associates, International Tax F-99, Lajpat Nagar-Ii, New Delhi New Delhi Pan : Aaact7216Q (Appellant) (Respondent) Deputy Commissioner Of Vs. Sabre Glbl Inc. Income Tax, Mr. Tarandeep Singh, Adv. International Taxation, C/O. Ms Associates, New Delhi F-99, Lajpat Nagar-Ii, New Delhi-110024 Pan : Aaact7216Q (Appellant) (Respondent) Assessee By Sh. Tarandeep Singh, Adv. Revenue By Sh. Vizay B. Vasanta, Cit-Dr

Section 143(2)Section 143(3)Section 144C(1)

above, the assessee shall be deemed to have a permanent establishment in India.” 28.6 The Tribunal next examined the question of existence of dependent agent PE and made following observations in para 17.3 and 17.4 ; “17.3 The next question arises is whether the assesee has a PE in India

Sabre Glbl Inc., New Delhi vs. DCIT (International Taxation), Circle- 3(1)(2), New Delhi

In the result, all the appeals of the assessee are allowed and that of the Revenue stands dismissed

ITA 4838/DEL/2017[2014-15]Status: HeardITAT Delhi09 Feb 2024AY 2014-15

Bench: Sh. G.S.Pannu, Hon’Ble & Sh. Anubhav Sharmaita No. 216/Del/2016, A.Y. 2012-13 Ita No. 559/Del/2017, A.Y. 2013-14 Ita No. 4838/Del/2017, A.Y. 2014-15 Ita No. 7724/Del/2018, A.Y. 2015-16 Ita No. 6040/Del/2019, A.Y. 2016-17 Sabre Glbl Inc. Vs. Asstt. Commissioner Of Income Mr. Tarandeep Singh, Tax, Adv. Circle-3(1)(2), C/O. Ms Associates, International Tax F-99, Lajpat Nagar-Ii, New Delhi New Delhi Pan : Aaact7216Q (Appellant) (Respondent) Deputy Commissioner Of Vs. Sabre Glbl Inc. Income Tax, Mr. Tarandeep Singh, Adv. International Taxation, C/O. Ms Associates, New Delhi F-99, Lajpat Nagar-Ii, New Delhi-110024 Pan : Aaact7216Q (Appellant) (Respondent) Assessee By Sh. Tarandeep Singh, Adv. Revenue By Sh. Vizay B. Vasanta, Cit-Dr

Section 143(2)Section 143(3)Section 144C(1)

above, the assessee shall be deemed to have a permanent establishment in India.” 28.6 The Tribunal next examined the question of existence of dependent agent PE and made following observations in para 17.3 and 17.4 ; “17.3 The next question arises is whether the assesee has a PE in India

Sabre Inc, New Delhi vs. DCIT (International Taxation), New Delhi

In the result, all the appeals of the assessee are allowed and that of the Revenue stands dismissed

ITA 216/DEL/2016[2012-13]Status: HeardITAT Delhi09 Feb 2024AY 2012-13

Bench: Sh. G.S.Pannu, Hon’Ble & Sh. Anubhav Sharmaita No. 216/Del/2016, A.Y. 2012-13 Ita No. 559/Del/2017, A.Y. 2013-14 Ita No. 4838/Del/2017, A.Y. 2014-15 Ita No. 7724/Del/2018, A.Y. 2015-16 Ita No. 6040/Del/2019, A.Y. 2016-17 Sabre Glbl Inc. Vs. Asstt. Commissioner Of Income Mr. Tarandeep Singh, Tax, Adv. Circle-3(1)(2), C/O. Ms Associates, International Tax F-99, Lajpat Nagar-Ii, New Delhi New Delhi Pan : Aaact7216Q (Appellant) (Respondent) Deputy Commissioner Of Vs. Sabre Glbl Inc. Income Tax, Mr. Tarandeep Singh, Adv. International Taxation, C/O. Ms Associates, New Delhi F-99, Lajpat Nagar-Ii, New Delhi-110024 Pan : Aaact7216Q (Appellant) (Respondent) Assessee By Sh. Tarandeep Singh, Adv. Revenue By Sh. Vizay B. Vasanta, Cit-Dr

Section 143(2)Section 143(3)Section 144C(1)

above, the assessee shall be deemed to have a permanent establishment in India.” 28.6 The Tribunal next examined the question of existence of dependent agent PE and made following observations in para 17.3 and 17.4 ; “17.3 The next question arises is whether the assesee has a PE in India

DCIT (International Taxation), New Delhi vs. M/S. Sabre Glbl Inc., Gurgaon

In the result, all the appeals of the assessee are allowed and that of the Revenue stands dismissed

ITA 6731/DEL/2015[2012-13]Status: HeardITAT Delhi09 Feb 2024AY 2012-13

Bench: Sh. G.S.Pannu, Hon’Ble & Sh. Anubhav Sharmaita No. 216/Del/2016, A.Y. 2012-13 Ita No. 559/Del/2017, A.Y. 2013-14 Ita No. 4838/Del/2017, A.Y. 2014-15 Ita No. 7724/Del/2018, A.Y. 2015-16 Ita No. 6040/Del/2019, A.Y. 2016-17 Sabre Glbl Inc. Vs. Asstt. Commissioner Of Income Mr. Tarandeep Singh, Tax, Adv. Circle-3(1)(2), C/O. Ms Associates, International Tax F-99, Lajpat Nagar-Ii, New Delhi New Delhi Pan : Aaact7216Q (Appellant) (Respondent) Deputy Commissioner Of Vs. Sabre Glbl Inc. Income Tax, Mr. Tarandeep Singh, Adv. International Taxation, C/O. Ms Associates, New Delhi F-99, Lajpat Nagar-Ii, New Delhi-110024 Pan : Aaact7216Q (Appellant) (Respondent) Assessee By Sh. Tarandeep Singh, Adv. Revenue By Sh. Vizay B. Vasanta, Cit-Dr

Section 143(2)Section 143(3)Section 144C(1)

above, the assessee shall be deemed to have a permanent establishment in India.” 28.6 The Tribunal next examined the question of existence of dependent agent PE and made following observations in para 17.3 and 17.4 ; “17.3 The next question arises is whether the assesee has a PE in India

Rga International Reinsurance Company Designated Activity Company, Ireland vs. Deputy Commissioner of Income Tax (International Taxation) - 4(1)(1), Mumbai, India

In the result, appeal filed by the assessee is allowed

ITA 3254/MUM/2023[2020-21]Status: DisposedITAT Mumbai31 Jan 2024AY 2020-21

Bench: Us, It Has Been Stated That This Issue Stands Covered By The Decision Of The Tribunal In Assessee’S Own Case For The A.Y.2018-19 & 2019-20 Which Has Followed Earlier Three Tribunal Orders.

Section 139Section 143(3)Section 9

that its operation neither constitute business connection in India nor does it has fixed place PE in India nor does it have a dependent agent PE in India for total income of Rs.14,46,73,768/- cannot be taxed. Before us, it has been stated that this issue stands covered ... refund 7. The ld. AO in the draft assessment order alleged that RGA International Reinsurance Company constitutes a fixed place PE in India dependent agent PE of RGA IRELAND in India. He has also alleged that unrelated three parties i.e. Indian Cedents constitutes DAPE of RGI IRELAND in India. Accordingly

Swiss Re Asia Pte Ltd, Mumbai vs. Dy CIT (International Taxation)-Circle -4(2)(2), Mumbai

Accordingly, Ground No. 1, 2, 3 and 5 are allowed

ITA 1492/MUM/2022[2018-19]Status: DisposedITAT Mumbai17 Jan 2024AY 2018-19

Bench: SHRI S. RIFAUR RAHMAN, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Percy PardiwalaFor Respondent: Shri Ashok Kumar Ambastha
Section 143(3)Section 144C(13)Section 144C(5)Section 234BSection 270Section 9(1)(i)

decisions leading to signing of the contract by the Appellant outside India without any further input outside India. SRCL-IB & SGB clearly constituted Dependent Agent PE of the Appellant in India. Therefore some part of the profits of the assessee on account of reinsurance premium is required to be attributed

Ge Energy Parts Inc., Noida vs. ACIT, Circle 1(3)(1), International Taxation, New Delhi

In the result, appeals of the assessee are allowed

ITA 738/DEL/2023[2020-21]Status: DisposedITAT Delhi17 Jan 2024AY 2020-21

Bench: Shri Saktijit Dey & Dr. B.R.R. Kumar

Section 285

judicial precedents cited before us. The short issue arising for consideration is whether the assessee had a PE, either fixed place PE or dependent agent PE, in India during the year under consideration. No doubt, the past assessment history of the assessee reveals that existence of PE in India ... impugned assessment year, it has to be concluded that the assessee did not have any PE, either fixed place PE or dependent agent PE, in India in the year under consideration. We again reiterate, our aforesaid conclusion is purely based on the facts involved in the impugned assessment year

Ge Energy Parts Inc., Noida vs. ACIT, Circle 1(3)(1), International Taxation, New Delhi

In the result, appeals of the assessee are allowed

ITA 737/DEL/2023[2016-17]Status: DisposedITAT Delhi17 Jan 2024AY 2016-17

Bench: Shri Saktijit Dey & Dr. B.R.R. Kumar

Section 285

judicial precedents cited before us. The short issue arising for consideration is whether the assessee had a PE, either fixed place PE or dependent agent PE, in India during the year under consideration. No doubt, the past assessment history of the assessee reveals that existence of PE in India ... impugned assessment year, it has to be concluded that the assessee did not have any PE, either fixed place PE or dependent agent PE, in India in the year under consideration. We again reiterate, our aforesaid conclusion is purely based on the facts involved in the impugned assessment year

Adobe Systems Software Ireland Ltd, Ireland vs. ACIT, Circle 1(1)(1), International Taxation, New Delhi

Appeal is allowed in terms indicate above

ITA 804/DEL/2023[2016-17]Status: DisposedITAT Delhi22 Dec 2023AY 2016-17

Bench: Shri Shamim Yahya & Shri Kul Bharat[Assessment Year : 2016-17] Adobe Systems Software Ireland Vs Acit, Ltd., 406, Riverwalk, Citywest Circle-1(1)(1), Business Campus, Saggart, International Dublin 24, Ireland Taxation, Pan-Aahca7203M New Delhi. Appellant Respondent Appellant By Shri Ravi Sharma, Adv. & Ms. Shruti Khimta, Ar Respondent By Shri Vizay B.Vasanta, Cit Dr Date Of Hearing 12.12.2023 Date Of Pronouncement 22.12.2023 Order Per Kul Bharat, Jm : The Present Appeal Filed By The Assessee Is Directed Against The Order Passed By Ld.Acit, Circle-International Taxation 1(1)(1), Delhi Dated 24.01.2023 For The Assessment Year 2016-17. 2. The Assessee Has Raised Following Grounds Of Appeal:-

That the Ld. AO and Hon'ble DRP grossly erred on the facts by concluding that Adobe India is a Dependent Agent PE of the Appellant and the agent is actively involved in sales and supply of software distributed by the Appellant, without appreciating that the sales and supply ... independent third-party distributors. 1.4. That the Ld. AO and Hon'ble DRP erred in law in holding Adobe India to be a Dependent Agent PE of the Appellant without bringing any cogent documentary evidence on record to substantiate the above statement. 1.5. That the Ld. AO erred

M/S. Exl Service.Com Llc, Mumbai vs. ADIT, New Delhi

In the result, the appeals of the assessee in ITA Nos

ITA 5628/DEL/2014[2005-06]Status: DisposedITAT Delhi20 Dec 2023AY 2005-06

Bench: Shri N.K. Billaiya & Ms Astha Chandra

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

considered view that the assessee does not have a fixed place PE in India, Service PE in India and dependent Agent PE in India. Therefore, no profit is attributable as no business connection has been established under Article 5 of the DTAA between India

M/S. Exl Service.Com Llc, Mumbai vs. ADIT, New Delhi

In the result, the appeals of the assessee in ITA Nos

ITA 5627/DEL/2014[2004-05]Status: DisposedITAT Delhi20 Dec 2023AY 2004-05

Bench: Shri N.K. Billaiya & Ms Astha Chandra

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

considered view that the assessee does not have a fixed place PE in India, Service PE in India and dependent Agent PE in India. Therefore, no profit is attributable as no business connection has been established under Article 5 of the DTAA between India

ADIT, New Delhi vs. M/S. Exl Service.Com Inc, Usa

In the result, the appeals of the assessee in ITA Nos

ITA 4989/DEL/2014[2005-06]Status: DisposedITAT Delhi20 Dec 2023AY 2005-06

Bench: Shri N.K. Billaiya & Ms Astha Chandra

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

considered view that the assessee does not have a fixed place PE in India, Service PE in India and dependent Agent PE in India. Therefore, no profit is attributable as no business connection has been established under Article 5 of the DTAA between India

M/S. Exl Service.Com Llc, Mumbai vs. ADIT, New Delhi

In the result, the appeals of the assessee in ITA Nos

ITA 3408/DEL/2014[2006-07]Status: DisposedITAT Delhi20 Dec 2023AY 2006-07

Bench: Shri N.K. Billaiya & Ms Astha Chandra

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

considered view that the assessee does not have a fixed place PE in India, Service PE in India and dependent Agent PE in India. Therefore, no profit is attributable as no business connection has been established under Article 5 of the DTAA between India

Exl Service.Com Inc, Mumbai vs. Addl. DIT Int. Taxation, New Delhi

In the result, the appeals of the assessee in ITA Nos

ITA 4183/DEL/2013[2003-04]Status: DisposedITAT Delhi20 Dec 2023AY 2003-04

Bench: Shri N.K. Billaiya & Ms Astha Chandra

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

considered view that the assessee does not have a fixed place PE in India, Service PE in India and dependent Agent PE in India. Therefore, no profit is attributable as no business connection has been established under Article 5 of the DTAA between India

Ge Global Parts & Products Gmbh, Switzerland vs. ACIT Circle 1(3)(1) International Taxation, New Delhi

In the result, appeal is allowed

ITA 736/DEL/2023[2020-21]Status: DisposedITAT Delhi29 Nov 2023AY 2020-21

Bench: Shri Saktijit Dey, Vice- & Shri M. Balaganeshassessment Year: 2020-21

Section 143(3)Section 144C(13)Section 5

judicial precedents cited before us. The short issue arising for consideration is whether the assessee had a PE, either fixed place PE or dependent agent PE, 4 | P a g e AY: 2020-21 in India during the year under consideration. No doubt, the past assessment history of the assessee ... impugned assessment year, it has to be concluded that the assessee did not have any PE, either fixed place PE or dependent agent PE, in India in the year under consideration. We again reiterate, our 6 | P a g e AY: 2020-21 aforesaid conclusion is purely based

Taj Tv Ltd., Mumbai vs. Dy CIT (It) 4(1)(2), Mumbai

In the result, the appeal by the assessee is allowed, while the appeal by the Revenue is dismissed

ITA 894/MUM/2020[2013-14]Status: DisposedITAT Mumbai26 Oct 2023AY 2013-14

Bench: Shri G.S. Pannu & Shri Sandeep Singh Karhail

For Appellant: Shri Madhur AgarwalFor Respondent: Shri Anil Sant
Section 250

IN THE INCOME TAX APPELLATE TRIBUNAL “I” BENCH, MUMBAI BEFORE SHRI G.S. PANNU, VICE PRESIDENT, AND SHRI SANDEEP SINGH KARHAIL

DCIT (It) 4(1)(2), Mumbai vs. Taj Tv Ltd., Mumbai

In the result, the appeal by the assessee is allowed, while the appeal by the Revenue is dismissed

ITA 1351/MUM/2020[2013-14]Status: DisposedITAT Mumbai26 Oct 2023AY 2013-14

Bench: Shri G.S. Pannu & Shri Sandeep Singh Karhail

For Appellant: Shri Madhur AgarwalFor Respondent: Shri Anil Sant
Section 250

IN THE INCOME TAX APPELLATE TRIBUNAL “I” BENCH, MUMBAI BEFORE SHRI G.S. PANNU, VICE PRESIDENT, AND SHRI SANDEEP SINGH KARHAIL