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“tax residency certificate”

International TaxSection 90(4)Section 90(4)328 judgments

SHRI RAM KRUPA MEDICARE PVT. LTD.,VADODARA vs. THE DY.CIT, CIRCLE-2(1)(1), VADODARA

In the result, the appeal of the assessee is allowed for statistical purpose

ITA 315/AHD/2026[2021-22]Status: DisposedITAT Ahmedabad09 Apr 2026AY 2021-22

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinhaassessment Years: 2021-22

Section 154Section 154(3)Section 195Section 200ASection 90Section 90(4)

DCIT, AY- 2021-22 3 4. The Ld CIT(A) failed to appreciate that the non-resident shareholders had duly furnished valid Tax Residency Certificate (TRC) and Form No. 10F and thereby fully complying with the conditions laid down under Section ... submitted that the information to be provided u/s. 90(5) of the Act in Form No. 10F as well as the tax residency certificate of the deductee was also brought on record. Therefore, the Ld. Addl. CIT(A) was not correct in upholding the rectification order of CPC-TDS. Shri

PHILIPS INDIA LIMITED,KOLKATA vs. A.C.I.T., CIRCLE - 11(1), KOLKATA

In the result, the appeals filed by the assessee for all the\n

ITA 1783/KOL/2024[2015-2016]Status: DisposedITAT Kolkata20 Mar 2026AY 2015-2016

Bench: The Tribunal Raising The\Nfollowing Grounds Of Appeal For Ay 2008-09 & More Or Less Similar\Ngrounds Of Appeal Have Been Raised In The Appeals For Other A.Ys. As\Nwell:\N\N“1. That On The Facts & Circumstances Of The Case, The National Faceless\Nappeal Centre, Delhi [The Ld. Cit(A)] Erred In Rejecting The Claim Of Refund\Nof Excess Dividend Distribution Tax (Ddt) Paid By The Appellant\Namounting To Rs.94,81,687.\N\N2. That On The Facts & Circumstances Of The Case, The Ld. Cit(A) Erred\Nin Following The Special Bench Decision Of Mumbai Tribunal In The Case Of\Ndcit Vs Tata Oil India Pvt Ltd (Ita No 6997/Mum/2019) Upholding That\Nddt Is A Tax On Profits Of The Domestic Company & Not On The\Nshareholder.\N\N2.

Section 115Section 244ASection 250

continuum from healthy living and prevention, to diagnosis,\ntreatment and home care. Philips Netherlands is a tax resident of\nNetherlands holding a valid Tax Residency Certificate ('TRC") issued\nby the Netherlands authorities. During the FY 2007-08, Philips\nNetherlands held 96.46% equity shares of the assessee. Furthermore,\nduring the year

PHILIPS INDIA LIMITED,KOLKATA vs. A.C.I.T., CIRCLE - 11(1), KOLKATA

In the result, the appeals filed by the assessee for all the assessment years i

ITA 1782/KOL/2024[2014-2015]Status: DisposedITAT Kolkata20 Mar 2026AY 2014-2015

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 115Section 237Section 244ASection 250

continuum from healthy living and prevention, to diagnosis, treatment and home care. Philips Netherlands is a tax resident of Netherlands holding a valid Tax Residency Certificate ('TRC") issued by the Netherlands authorities. During the FY 2007-08, Philips Netherlands held 96.46% equity shares of the assessee. Furthermore, during the year

PHILIPS INDIA LIMITED,KOLKATA vs. A.C.I.T., CIRCLE - 11(1), KOLKATA

In the result, the appeals filed by the assessee for all the assessment years i

ITA 1781/KOL/2024[2013-2014]Status: DisposedITAT Kolkata20 Mar 2026AY 2013-2014

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 115Section 237Section 244ASection 250

continuum from healthy living and prevention, to diagnosis, treatment and home care. Philips Netherlands is a tax resident of Netherlands holding a valid Tax Residency Certificate ('TRC") issued by the Netherlands authorities. During the FY 2007-08, Philips Netherlands held 96.46% equity shares of the assessee. Furthermore, during the year

PHILIPS INDIA LIMITED,KOLKATA vs. A.C.I.T., CIRCLE - 11(1),, KOLKATA

In the result, the appeals filed by the assessee for all the assessment years i

ITA 1780/KOL/2024[2012-2013]Status: DisposedITAT Kolkata20 Mar 2026AY 2012-2013

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 115Section 237Section 244ASection 250

continuum from healthy living and prevention, to diagnosis, treatment and home care. Philips Netherlands is a tax resident of Netherlands holding a valid Tax Residency Certificate ('TRC") issued by the Netherlands authorities. During the FY 2007-08, Philips Netherlands held 96.46% equity shares of the assessee. Furthermore, during the year

PHILIPS INDIA LIMITED,KOLKATA vs. A.C.I.T., CIRCLE - 11(1), , KOLKATA

In the result, the appeals filed by the assessee for all the\n

ITA 1779/KOL/2024[2011-2012]Status: DisposedITAT Kolkata20 Mar 2026AY 2011-2012

Bench: The Tribunal Raising The\Nfollowing Grounds Of Appeal For Ay 2008-09 & More Or Less Similar\Ngrounds Of Appeal Have Been Raised In The Appeals For Other A.Ys. As\Nwell:\Nita No(S). 1776 To 1783/Kol/2024\N Assessment Year(S) 2008-09 To 2015-16\Nphilips India Limited.\N1. That On The Facts & Circumstances Of The Case, The National Faceless\Nappeal Centre, Delhi [The Ld. Cit(A)] Erred In Rejecting The Claim Of Refund\Nof Excess Dividend Distribution Tax (Ddt) Paid By The Appellant\Namounting To Rs.94,81,687.\N2. That On The Facts & Circumstances Of The Case, The Ld. Cit(A) Erred\Nin Following The Special Bench Decision Of Mumbai Tribunal In The Case Of\Ndcit Vs Tata Oil India Pvt Ltd (Ita No 6997/Mum/2019) Upholding That\Nddt Is A Tax On Profits Of The Domestic Company & Not On The\Nshareholder.\N2.

Section 115Section 244ASection 250

continuum from healthy living and prevention, to diagnosis,\ntreatment and home care. Philips Netherlands is a tax resident of\nNetherlands holding a valid Tax Residency Certificate ('TRC") issued\nby the Netherlands authorities. During the FY 2007-08, Philips\nNetherlands held 96.46% equity shares of the assessee. Furthermore,\nduring the year

PHILIPS INDIA LTD.,KOLKATA vs. A.C.I.T., CIRCLE - 11(1), , KOLKATA

In the result, the appeals filed by the assessee for all the\n

ITA 1778/KOL/2024[2010-2011]Status: DisposedITAT Kolkata20 Mar 2026AY 2010-2011

Bench: The Tribunal Raising The\Nfollowing Grounds Of Appeal For Ay 2008-09 & More Or Less Similar\Ngrounds Of Appeal Have Been Raised In The Appeals For Other A.Ys. As\Nwell:\Npage | 2\Nita No(S). 1776 To 1783/Kol/2024\N Assessment Year(S) 2008-09 To 2015-16\Nphilips India Limited.\N“1. That On The Facts & Circumstances Of The Case, The National Faceless\Nappeal Centre, Delhi [The Ld. Cit(A)] Erred In Rejecting The Claim Of Refund\Nof Excess Dividend Distribution Tax (Ddt) Paid By The Appellant\Namounting To Rs.94,81,687.\N2. That On The Facts & Circumstances Of The Case, The Ld. Cit(A) Erred\Nin Following The Special Bench Decision Of Mumbai Tribunal In The Case Of\Ndcit Vs Tata Oil India Pvt Ltd (Ita No 6997/Mum/2019) Upholding That\Nddt Is A Tax On Profits Of The Domestic Company & Not On The\Nshareholder.\N2.

Section 115Section 244ASection 250

continuum from healthy living and prevention, to diagnosis,\ntreatment and home care. Philips Netherlands is a tax resident of\nNetherlands holding a valid Tax Residency Certificate ('TRC") issued\nby the Netherlands authorities. During the FY 2007-08, Philips\nNetherlands held 96.46% equity shares of the assessee. Furthermore,\nduring the year

PHILIPS INDIA LIMITED,KOLKATA vs. A.C.I.T., CIRCLE - 11(1), KOLKATA

In the result, the appeals filed by the assessee for all the assessment years i

ITA 1777/KOL/2024[2009-2010]Status: DisposedITAT Kolkata20 Mar 2026AY 2009-2010

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 115Section 237Section 244ASection 250

continuum from healthy living and prevention, to diagnosis, treatment and home care. Philips Netherlands is a tax resident of Netherlands holding a valid Tax Residency Certificate ('TRC") issued by the Netherlands authorities. During the FY 2007-08, Philips Netherlands held 96.46% equity shares of the assessee. Furthermore, during the year

PHILIPS INDIA LIMITED,KOLKATA vs. A.C.I.T., CIRCLE - 11(1), KOLKATA

In the result, the appeals filed by the assessee for all the\n

ITA 1776/KOL/2024[2008-2009]Status: DisposedITAT Kolkata20 Mar 2026AY 2008-2009

Bench: The Tribunal Raising The\Nfollowing Grounds Of Appeal For Ay 2008-09 & More Or Less Similar\Ngrounds Of Appeal Have Been Raised In The Appeals For Other A.Ys. As\Nwell:\Nita No(S). 1776 To 1783/Kol/2024\N Assessment Year(S) 2008-09 To 2015-16\Nphilips India Limited.\N“1. That On The Facts & Circumstances Of The Case, The National Faceless\Nappeal Centre, Delhi [The Ld. Cit(A)] Erred In Rejecting The Claim Of Refund\Nof Excess Dividend Distribution Tax (Ddt) Paid By The Appellant\Namounting To Rs.94,81,687.\N2. That On The Facts & Circumstances Of The Case, The Ld. Cit(A) Erred\Nin Following The Special Bench Decision Of Mumbai Tribunal In The Case Of\Ndcit Vs Tata Oil India Pvt Ltd (Ita No 6997/Mum/2019) Upholding That\Nddt Is A Tax On Profits Of The Domestic Company & Not On The\Nshareholder.\N2.

Section 115Section 244ASection 250

continuum from healthy living and prevention, to diagnosis,\ntreatment and home care. Philips Netherlands is a tax resident of\nNetherlands holding a valid Tax Residency Certificate ('TRC") issued\nby the Netherlands authorities. During the FY 2007-08, Philips\nNetherlands held 96.46% equity shares of the assessee. Furthermore,\nduring the year

SERCEL SA ,DEHRADUN vs. DCIT, CIRCLE-2, DDN, DEHRADUN

In the result, the appeal of the assessee is allowed

ITA 59/DDN/2023[2020-21]Status: DisposedITAT Dehradun13 Mar 2026AY 2020-21

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahman

Section 142(1)Section 143(3)Section 195Section 44BSection 9(1)(i)

manufacturing seismic equipment required for hydrocarbon exploration in land, transition zone, ocean-bottom cable, marine, and downhole environments. The assessee is submitted its Tax Residency Certificate (TRC) issued by the Government of France for the year 2020 & 2021. During the year under consideration, the assessee was engaged in executing supply

GE ENGINE SERVICES LLC,UNITED STATES OF AMERICA vs. ASSISTANT COMMISSIONER OF INCOME TAX, NEW DELHI

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

ITA 3700/DEL/2023[AY 2021-22]Status: DisposedITAT Delhi11 Mar 2026
Section 143(2)Section 143(3)Section 144CSection 9(1)

income earned by the assessee was\nthus taxed in the hands of its sole member i.e. General Electric Company. A copy of\nthe Tax Residency Certificate (TRC) was also attached at Page No 24-25 of the Paper\nBook. On the perusal of the above certificate, it is seen that ... tax resident of USA under Article 4 of the India-USA Double Tax Avoidance Agreement\n(‘DTAA'). Copy of the tax residency certificate for the relevant period is attached at Page No 24-25 of\nthe Paper Book.\n16 The Appellant is one of the leading providers of aircraft engine

AMIT SATPATHY,MUMBAI vs. ITO-42(2)(1), MUMBAI

In the result, the appeal by the assessee is allowed for statistical purposes

ITA 5930/MUM/2025[2017-18]Status: DisposedITAT Mumbai27 Feb 2026AY 2017-18

Bench: Shri Om Prakash Kantshri Sandeep Singh Karhailamit Satpathy, Flat No.404, Tower A, Imperial Heights, Oshirwara, Goregaon (West) ……………. Appellant Mumbai – 400104 Pan: Arrps8419D V/S Deputy Commissioner Of Income Tax, Central Processing Centre, Assistant Director Of Income Tax, …………….Respondent Central Processing Centre, Income Tax Department, Bengaluru - 560500

For Appellant: Shri Siddhesh ChauguleFor Respondent: Shri Krishna Kumar, Sr. DR
Section 143(1)Section 234BSection 250Section 90(2)

Income Tax Act, 1961 ("the Act') read with the Article 16(1) of DTAA between India and UK, despite producing the Tax Residency Certificate issued by UK Authorities during the course of appeal proceedings. 1.3 In the facts and in the circumstances of the case ... DTAA, the salary can only be taxed in India. The learned CIT(A) also rejected the reliance placed by the assessee on the Tax Residency Certificate of the UK issued up to the period 17.07.2016. The relevant findings of the learned CIT(A), vide impugned order, are reproduced as follows

BOBST BIELEFELD GMBH,GERMANY vs. THE ASSISTANT COMMISSIONER OF INCOME TAX INT TAX CIRCLE 1(3)(1), MUMBAI, MUMBAI

ITA 6030/MUM/2025[2018-19]Status: DisposedITAT Mumbai26 Feb 2026AY 2018-19

Bench: Justice (Retd.) Shri C.V. Bhadang & Shri Vikram Singh Yadav

For Appellant: Shri Siddesh ChauguleFor Respondent: Shri Krishna Kumar, Sr.DR
Section 234Section 234ASection 270A

course of assessment proceedings, in response to notice issued u/s 143(2), submitted that it is tax resident of Germany (copy of tax residency certificate was furnished), has no office/permanent establishment in India and it provides professional consultancy services from Germany only as and when required by Indian clients ... India and to avail the beneficial tax rate of 10% as per Article 12 of India-German tax treaty and copy of tax residency certificate was also furnished. The AO has also recorded his findings stating that the assessee is a resident of Germany and provides all professional however

BOBST BIELEFELD GMBH,GERMANY vs. THE ASSISTANT COMMISSIONER OF INCOME TAX INT TAX CIRCLE 1(3)(1), MUMBAI, MUMBAI

ITA 6029/MUM/2025[2017-18]Status: DisposedITAT Mumbai26 Feb 2026AY 2017-18

Bench: Justice (Retd.) Shri C.V. Bhadang & Shri Vikram Singh Yadav

For Appellant: Shri Siddesh ChauguleFor Respondent: Shri Krishna Kumar, Sr.DR
Section 234Section 234ASection 270A

course of assessment proceedings, in response to notice issued u/s 143(2), submitted that it is tax resident of Germany (copy of tax residency certificate was furnished), has no office/permanent establishment in India and it provides professional consultancy services from Germany only as and when required by Indian clients ... India and to avail the beneficial tax rate of 10% as per Article 12 of India-German tax treaty and copy of tax residency certificate was also furnished. The AO has also recorded his findings stating that the assessee is a resident of Germany and provides all professional however

DCIT(IT)-4(1)(2), MUMBAI vs. ARUN MADHAVACHARI RANGACHARI, MUMBAI

ITA 3814/MUM/2025[2011-12]Status: DisposedITAT Mumbai26 Feb 2026AY 2011-12
For Appellant: Shri Gaurav KabraFor Respondent: Shri Ajay Chandra, CIT-DR
Section 250Section 254Section 9(1)(vii)

whether the\nassessee is a resident under Article 4 of that DAA and without appreciating the\nfact that the assessee had not provided Tax Residency Certificate from UAE\nTax Authority?\"\n3) \"Without prejudice to the above, even if it is found that the India-UAE DTAA\nis applicable, whether ... Services\nu/s 9(1)(vii) of the IT Act without appreciating that the services have been\nutilized in India and in absence of Tax Residency Certificate, the benefit of\nIndia UAE DTAA cannot be extended to the assessee?\"\n6) \"Whether on the facts and circumstance of the case

DCIT (INTERNATIONAL TAXATION)-2, HYDERABAD vs. THOGARCHEDU SUBHA SRI, HYDERABAD

In the result, the appeal of the Revenue is dismissed

ITA 1058/HYD/2025[2023-24]Status: DisposedITAT Hyderabad11 Feb 2026AY 2023-24
For Appellant: Shri BG Reddy, AdvocateFor Respondent: : Dr. Sachin Kumar, Sr. AR
Section 115A(1)(a)Section 143(1)Section 154Section 90(4)Section 90(5)

rates as per the Double Taxation Avoidance Agreement (DTAA)\nwith USA without appreciating the fact that the assessee failed to\nsubmit/provide the requisite Tax Residency Certificate as provided u/s.90(4)\nand Form 10F as provided u/s.90(5) of the Income Tax Act, 1961 on or before\nthe filing of return ... Income Tax Act, 1961 clearly states that the\nassessee 'shall not be entitled to claim any relief under such agreement' unless\nthe Tax Residency Certificate and Form 10F furnished?\n4. Any other ground of appeal that may be raised with the prior approval of the\nHon'ble ITAT during

ROHAN LANDSCAPE PRIVATE LIMITED,MUMBAI vs. THE PRINCIPLE COMMISSIONER OF INCOME TAX, , MUMBAI

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

ITA 3635/MUM/2025[2020-21]Status: DisposedITAT Mumbai10 Feb 2026AY 2020-21

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI ARUN KHODPIA (Accountant Member)

Section 139(1)Section 142(1)Section 143(2)Section 263Section 3

audited financial statements of the shareholders, PAN details, certificates of incorporation, and in the case of the foreign shareholder, Foreign Inward Remittance Certificates, tax residency certificates and audited accounts demonstrating sufficient net worth and creditworthiness. The assessee emphasised that the transactions were genuine, routed through banking channels, and fully supported ... shareholders, including board resolutions, bank statements, audited financial statements, PAN, certificates of incorporation, and in the case of the foreign shareholder, FIRC and tax residency certificates. The shares were issued to existing shareholders in proportion to their shareholding and through banking channels. The learned Principal Commissioner has 17 Rohan Landscape

HAREON SOLAR SINGAPORE PRIVATE LIMITED,SINGAPORE vs. DCIT INT. TAXATION CIRCLE-2(1)(1), NEW DELHI

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

ITA 2226/DEL/2024[2020-21]Status: DisposedITAT Delhi30 Jan 2026AY 2020-21
Section 112Section 143(3)Section 144C(5)

Beach Tower,\nSingapore. The assessee has claimed that it is Tax Resident of Singapore. It is\nalso observed that the assessee has submitted Tax Residency Certificate(TRC)\ndated 31.07.2019(Tax Reference No. 201510860M/PB-Page 177/178) issued by\nthe Singapore Revenue Authorities, confirming that the assessee will be regarded\nas resident

FORT CANNING CREDIT INVESTMENTS PTE. LTD.,SINGAPORE vs. ASSISTANT COMMISSIONER OF INCOME-TAX (INTERNATIONAL TAXATION) - 2(3)(1), MUMBAI, MUMBAI

In the result, appeal of the assessee is allowed

ITA 2104/MUM/2025[2022-23]Status: DisposedITAT Mumbai27 Jan 2026AY 2022-23

Bench: Shri Amit Shukla & Shri Girish Agrawalassessment Year: 2022-23 Fort Canning Investments Assistant Commissioner Of Pte. Ltd. Income-Tax (International 260 Orchard Road, #14-02 Taxation) - 2(3)(1) Vs. The Heeren, Singapore, Mumbai Singapore – 238855 (Pan: Aaccf9284G) (Appellant) (Respondent) Assessment Year: 2022-23 Fort Canning Credit Assistant Commissioner Of Investments Pte. Ltd. Income-Tax (International 260 Orchard Road #14-02 Taxation) - 2(3)(1) Vs. The Heeren, Singapore, Mumbai Singapore – 238855 (Pan: Aadcf7866R) (Appellant) (Respondent) Present For: Assessee : Shri Dhanesh Bafna, Ms. Priyanka Agarwala, Ms.Hirali Desai, Ms. Nidhi Agarwal & Shri Yogesh Malpani, Cas Revenue : Shri Satya Pal Kumar, Cit Dr & Shri Krishna Kumar, Sr. Dr Date Of Hearing : 29.10.2025 Date Of Pronouncement : 27.01.2026 Fort Canning Investments Pte. Ltd. & Fort Canning Credit Investments Pte. Ltd. Ay 2022-23

For Appellant: Shri Dhanesh BafnaFor Respondent: Shri Satya Pal Kumar, CIT DR and Shri Krishna Kumar, Sr. DR
Section 143(3)Section 144C(13)Section 144C(5)Section 234BSection 270A

other assessee. 4. Brief facts of the case are that assessee is a tax resident of Singapore and holds a valid Tax Residency Certificate (TRC) issued by the Tax Authority in Singapore covering the period under consideration. It is registered with Securities and Exchange Board of India (SEBI

FORT CANNING INVESTMENTS PTE. LTD. ,SINGAPORE vs. ASSISTANT COMMISSIONER OF INCOME-TAX (INTERNATIONAL TAXATION) - 2(3)(1), MUMBAI, MUMBAI

In the result, appeal of the assessee is allowed

ITA 2103/MUM/2025[2022-23]Status: DisposedITAT Mumbai27 Jan 2026AY 2022-23

Bench: Shri Amit Shukla & Shri Girish Agrawalassessment Year: 2022-23 Fort Canning Investments Assistant Commissioner Of Pte. Ltd. Income-Tax (International 260 Orchard Road, #14-02 Taxation) - 2(3)(1) Vs. The Heeren, Singapore, Mumbai Singapore – 238855 (Pan: Aaccf9284G) (Appellant) (Respondent) Assessment Year: 2022-23 Fort Canning Credit Assistant Commissioner Of Investments Pte. Ltd. Income-Tax (International 260 Orchard Road #14-02 Taxation) - 2(3)(1) Vs. The Heeren, Singapore, Mumbai Singapore – 238855 (Pan: Aadcf7866R) (Appellant) (Respondent) Present For: Assessee : Shri Dhanesh Bafna, Ms. Priyanka Agarwala, Ms.Hirali Desai, Ms. Nidhi Agarwal & Shri Yogesh Malpani, Cas Revenue : Shri Satya Pal Kumar, Cit Dr & Shri Krishna Kumar, Sr. Dr Date Of Hearing : 29.10.2025 Date Of Pronouncement : 27.01.2026 Fort Canning Investments Pte. Ltd. & Fort Canning Credit Investments Pte. Ltd. Ay 2022-23

For Appellant: Shri Dhanesh BafnaFor Respondent: Shri Satya Pal Kumar, CIT DR and Shri Krishna Kumar, Sr. DR
Section 143(3)Section 144C(13)Section 144C(5)Section 234BSection 270A

other assessee. 4. Brief facts of the case are that assessee is a tax resident of Singapore and holds a valid Tax Residency Certificate (TRC) issued by the Tax Authority in Singapore covering the period under consideration. It is registered with Securities and Exchange Board of India (SEBI

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