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“tax residency certificate”

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

The decision most relied on for tax residency certificate is CIT v. Kotak Securities Ltd. (340 ITR 333), cited in 161 judgments on BharatTax.

Leading authorities on tax residency certificate

CIT v. Kotak Securities Ltd.
340 ITR 333 · 2012 · High Court
161
citing judgments

A deductor's bonafide belief or reliance on a Tax Residency Certificate (TRC) can influence whether they are deemed an 'assessee in default' under Section 195 for failing to deduct tax at source on payments to non-residents. The decision clarifies the due diligence required when interpreting tax treaties and TRCs for TDS compliance.

Sanofi Pasteur Holding SA v. Department of Revenue
354 ITR 316 · 2013 · High Court
42
citing judgments

Gains from the indirect transfer of shares in a foreign company holding Indian shares are not taxable in India under the relevant tax treaty, which is considered a self-contained code to be interpreted plainly. Creating corporate structures or special purpose vehicles for investment to secure tax benefits is a legitimate business activity.

Edenred Pte. Ltd. v. Deputy Director of Income Tax (International
118 Taxmann.com 2 · 2020 · Reported
14
citing judgments

The case is authority for the proposition that where a tax treaty provides for a more beneficial treatment than the Income Tax Act, the treaty provisions will prevail, provided certain conditions under section 90(2) are met.

Judgments citing tax residency certificate

Hero Fincorp Limited, New Delhi vs. ACIT, Circle 11(1), Delhi, C.R. Building

ITA 2542/DEL/2024[2017-18]Status: DisposedITAT Delhi16 Jan 2026AY 2017-18

Bench: Shri Mahavir Singh, Vice Presdient (), Shri Satbeer Singh Godara & Shri Brajesh Kumar Singhआ.अ.सं/.I.T.A No.2542/Del/2024 निर्धारणवर्ष/Assessment Year:2017-18 Hero Fincop Ltd., 34 Community Centre, Basant Lok, Vasant Vihar, New Delhi-110057 बनाम Vs. Assistant Commissioner Of Income Tax, Circle-11(1) C. R. Building, New Delhi-110002 अपीलार्थी Appellant प्रत्यर्थी/Respondent Pan:Aaach0157J Assessee By Shri Rohit Jain, Adv., Shri Deepesh Jain, Adv. & Shri Himanshu Aggarwal Adv. Revenue By Ms. Pooja Swaroop, Cit(Dr) सुनवाईकीतारीख / Date Of Hearing: 14.01.2026 उद्घोषणाकीतारीख/Pronouncement On 16.01.2026 आदेश /Order Per Brajesh Kumar Singh, Am, The Assessee Is Engaged In The Business Of ‘Hire Purchase Leasing & Finance'. This Appeal Is Filed By The Assessee Against The Order Of National Faceless Appeal Center (Nfac)/(First Appellate Authority Hereinafter Referred As “Faa”), Delhi Dated 27.03.2024 Arising Out Of Assessment Order U/S 143(3) Of The Act Dated 29.12.2019For The Assessment Year 2017-18. 2. The Assessee Has Raised Following Grounds Of Appeal: “Disallowance Of Provision For Collection Charges -Rs. 9,75,00,000/-

Section 143(3)Section 154Section 251(1)Section 56(2)(viib)

subscribers i.e. non-resident allottees along with their addresses, number of shares issued, amount subscribed by each subscriber, Foreign Inward Remittance Certificates (FIRC), Tax Residency Certificates (TRC) were placed on already on record. 18. That the NFAC grossly erred on facts and in law in not appreciating that the certificates

Bharti Airtel Ltd, New Delhi vs. ITO, TDS, Ward-1(1), International Taxation, New Del;Hi

In the result, ground of appeal no

ITA 4580/DEL/2017[2009-10]Status: DisposedITAT Delhi06 Jan 2026AY 2009-10

Bench: Shri Vikas Awasthy & Shri Manish Agarwalआअसं.4580/धिल्ली/2017(नि.व. 2009-10) Bharti Airtel Ltd., Bharti Crescent, 1 Nelson Mandela Road, Vasant Kunj, Phase Ii, New Delhi 110070 ...... अपीलार्थी/Appellant Pan: Aaacb-2894-G बिाम Vs. Income Tax Officer, Tds, Ward 1(1), International Taxation, ..... प्रनिवादी/Respondent New Delhi अपीलार्थी द्वारा/ Appellant By : Shri Anil Bhalla, Chartered Accountant प्रधििािीद्वारा/Respondent By : Shri Vikram Singh Sharma, Sr. Dr सुिवाई की निथर्थ/ Date Of Hearing : 09/10/2025 घोषणा की निथर्थ/ Date Of Pronouncement : 06/01/2026 आदेश/Order Per Vikas Awasthy, Jm:

For Appellant: Shri Anil Bhalla, Chartered AccountantFor Respondent: Shri Vikram Singh Sharma, Sr. DR
Section 201(1)

retention. The assessee on the basis of a letter from ABN Amro dated 12.09.2002 (at page 662 of the paper book) and Tax Residency Certificate (TRC) issued by Swedish Tax Authorities dated 11.09.2002 (at page 661 of the paper book) and dated 14.03.2007 (at page 431 to paper book ... decide the domicile residency of the foreign entity. The ld. AR pointed that the communication from Swedish Tax Authority dated 17.04.2008, clarifying that Tax Residency Certificate issued to ABN AMRO Bank, NV, Stockholm Branch was wrongly issued, was received by the assessee after the assessee had already made the payment

G S Strategic Investments Limited, Mumbai vs. ACIT International Tax Circle 2(3)(2), Mumbai

In the result, the appeal of the assessee is allowed

ITA 5644/MUM/2025[2023-24]Status: DisposedITAT Mumbai30 Dec 2025AY 2023-24

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 112Section 143(3)Section 144C(13)Section 74

under the Foreign Direct Investment route. The assessee is a tax resident of Mauritius and holds a valid 3 GS Strategic Investments Limited Tax Residency Certificate, which has not been controverted by the Revenue. 4. During the financial year ended 31 March 2023, relevant to the assessment year

Acronis Asia Pte Ltd, Mumbai vs. Deputy Commissioner of Income Tax (International Taxation )Range-1(1)(1), Mumbai

In the result, the appeal filed by the assessee is

ITA 2035/MUM/2025[2022-23]Status: DisposedITAT Mumbai30 Dec 2025AY 2022-23
Section 10(50)Section 143(3)Section 144C(13)

company incorporated under the laws of Singapore on 4 November 2004 and is an undisputed tax resident of Singapore. It holds a valid Tax Residency Certificate issued by the Singapore tax authorities for the relevant calendar years and, therefore, is entitled to claim benefits under the India-Singapore Double Taxation ... Singapore, carrying on business in its own right, employing its own personnel, maintaining its own books of account, and holding a valid Tax Residency Certificate issued by the Singapore tax authorities. The assessee has existed since 2004 and has been engaged in distribution activity for the Asia Pacific and Japan

Asia Today Ltd, Mumbai vs. ADIT (It) 2(2), Mumbai

In the result, Assessee's appeal is allowed

ITA 1403/MUM/2008[2004-2005]Status: DisposedITAT Mumbai24 Dec 2025AY 2004-2005

Bench: Shri Narender Kumar Choudhry & Shri Omkareshwar Chidaraassessment Year: 2004-05 M/S. Asia Today Limited, Asst. Director Of Income C/O. Zee Entertainment Enterprises Tax (International Ltd., Vs. Taxation)-2(2), 135, Dr. Annie Besant Road, Scindia House, Worli, Mumbai – 400 018 Bellard Estate, Pan: Aabca0249F Mumbai - 400039 (Appellant) (Respondent) Present For: Assessee By : Shri Niraj Sheth, Ld. A.R. Revenue By : Shri Krishna Kumar, Ld. Sr. D.R. Date Of Hearing : 10.10.2025 Date Of Pronouncement : 24.12.2025 O R D E R Per : Narender Kumar Choudhry: This Appeal Has Been Preferred By The Assessee Against The Order Dated 25.01.2007, Impugned Herein, Passed By The Ld. Commissioner Of Income Tax (Appeals) (In Short Ld. Commissioner) U/S 250 Of The Income Tax Act, 1961 (In Short ‘The Act’) For The A.Y. 2004-05. 2. The Relevant Facts For Adjudication Of This Appeal Are As Under: The Assessee, Being A Foreign Telecasting Company Incorporated In Mauritius & Having Tax Residency Certificate Of Mauritius , During The Ay Under Consideration Was Engaged In The Production & Acquiring Rights Of Various Television Films Including Feature Films, As A Copy Right Owner/Holder Of Various Hindi Feature Films Produced & Censored In India, As Mentioned In Schedule ‘C’ Annexed With The ‘Agreement Of 2 M/S Asia Today Ltd. Vs Asst. Dit (Int. Taxation)-2(2)

For Appellant: Shri Niraj Sheth, Ld. A.RFor Respondent: Shri Krishna Kumar, Ld. Sr. D.R
Section 250Section 9(1)(vi)

relevant facts for adjudication of this appeal are as under: The Assessee, being a foreign telecasting company incorporated in Mauritius and having tax residency certificate of Mauritius , during the AY under consideration was engaged in the production and acquiring rights of various television films including feature films, as a copy ... into between ESS Distribution (Mauritius) S.N.C. ET Compagnie³, ESPN Star Sports and ESPN Software India Private Limited. ESS Distribution (Mauritius) holds a valid Tax Residency Certificate and claims benefits in terms of the provisions contained in the India -Mauritius Double Taxation Avoidance Agreement. The subject matter of the agreements executed

Federal Mogul Holdings, Ltd, Mauritius vs. ACIT Circle Intl Tax 1(3)(1), New Delhi

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

ITA 4180/DEL/2025[2018-19]Status: DisposedITAT Delhi23 Dec 2025AY 2018-19

Bench: Shri Vikas Awasthy & Shri Brajesh Kumar Singh

Section 143(1)Section 154

considered as well as the detailed set of numbered documents in support of its claim as filed by the appellant containing copy of tax residency certificate copy of intimation order/rectification orders issued from time to time, copy of the financial statements of FM Powertrain, etc. 7.8 Further, on perusal

Mariappan Austin Prakash, Bengaluru, Kanrnataka vs. Assistant Commissioner of Income Tax, Intl Txn Circle, Visakhapatnam

In the result, appeal of the assessee is allowed

ITA 89/VIZ/2025[2022-23]Status: DisposedITAT Visakhapatnam05 Dec 2025AY 2022-23

Bench: Shri Ravish Sood, Hon’Ble

Section 142(1)Section 143Section 143(2)Section 143(3)Section 144C(1)Section 144C(13)Section 144C(5)Section 195Section 9(1)(i)

response submitted that he has stayed in India less than sixty (60) days during the impugned assessment year and further submitted the Tax Residency Certificate [in short “TRC”] issued by Dubai Tax Authorities. Further, he also submitted the residential documents claiming that he is a citizen of Singapore ... establishment as per Article 5 of the India-UAE DTAA being determined in the case of the Appellant, and more so when the Tax Residency Certificate from the Federal Tax Authority of the UAE and Form 10F, on the basis of which the residential status of the Appellant was determined

DCIT CC 7(2).Mumbai, Mumbai vs. Man Industries (India) Limited, Mumbai

In the result, the appeal of the Revenue is allowed

ITA 619/MUM/2025[2020-21]Status: DisposedITAT Mumbai24 Nov 2025AY 2020-21

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2020-2021

For Respondent: Mr. K. Gopal
Section 14ASection 194ASection 40

year under consideration, the appellant has relied upon discussed above. For the year under consideration, the appellant has relied upon the Tax Residency Certificate dated 14.05.2019 issued by the Dy. Commissioner the Tax Residency Certificate dated 14.05.2019 issued by the Dy. Commissioner the Tax Residency Certificate dated 14.05.2019 issued

Valuzhathil Padmanabhan Sivadasan, Thiruvalla vs. Income Tax Officer, Ward-2, Thiruvalla

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

ITA 770/COCH/2025[2015-16]Status: DisposedITAT Cochin21 Nov 2025AY 2015-16

Bench: Shri Inturi Rama Rao, Am Assessment Year: 2015-16 Valuzhathil Padmanabhan Sivadasan .......... Appellant Valuzhathil House, Kozhuvalloor, Thiruvalla [Pan: Akaps3606C] Vs. The Income Tax Officer, Ward-2, Thiruvalla .......... Respondent Assessee By: Shri Stephen George, Ar Revenue By: Smt. Leena Lal, Sr. D.R. Date Of Hearing: 06.11.2025 Date Of Pronouncement: 21.11.2025 O R D E R This Appeal Filed By The Assessee Is Directed Against The Order Of The Commissioner Of Income Tax (Appeals)-2, Noida [Cit(A)] Dated 25.08.2025 For Assessment Year (Ay) 2015-16. 2. Brief Facts Of The Case Are That The Appellant Is A Non-Resident Indian. No Regular Return Of Income Under The Provisions Of Section 139(1) Of The Income Tax Act, 1961 (The Act) Was Filed By The Appellant. The Dcit (International Taxation) Lkn (Hereinafter Called "The Ao"), Based On The Information That The Appellant Made Term Deposits In Bank & Earned Interest Income Of Deposits, Formed An Opinion That Income Escaped Assessment To Tax. Accordingly, The 2 Valuzhathil Padmanabhan Sivadasan Ao Issued A Notice U/S. 148 Of The Act After Duly Complying The Provisions Of Section 148(A) Of The Act. In Response To The Notice U/S. 148, The Appellant Filed Return Of Income For Ay 2016-17 On 30.08.2022 Declaring Total Income Of Rs. 2,44,870/-. Against The Said Return Of Income, The Assessment Was Completed By The Ao Vide Order Dated 26.05.2023 Passed U/S. 147 R.W.S. 144C(3) Of The Act At Total Income Of Rs. 35,01,948/-. While Doing So, The Ao Brought To Tax The Income Of Salary Of Rs. 32,57,078/-.

For Appellant: Shri Stephen George, ARFor Respondent: Smt. Leena Lal, Sr. D.R
Section 139(1)Section 147Section 148Section 4(1)(a)

order confirmed the action of the AO solely on the ground that the appellant had failed to file copy of the passport and Tax Residency Certificate to prove that he was NRI. 4. Being aggrieved, the appellant is in appeal before this Tribunal in the present appeal. 5. The only

DCIT Circle 1(1), New Delhi vs. Acme Tele Power Ltd. (Now Known As Acme Cleantech Solution Ltd.), New Delhi

In the result, appeal of the Revenue is dismissed

ITA 1074/DEL/2023[2010-11]Status: DisposedITAT Delhi20 Nov 2025AY 2010-11

Bench: Shri Sudhir Pareek & Shri Manish Agarwal[Assessment Year : 2011-12] M/S. Acme Cleantech Solutions Vs Dcit, Ltd., C/O-M/S. Rra Taxindia, Circle-1(2) D-28, South Extension, Part-1, New Delhi New Delhi-110049 Pan-Aaeca0914A Appellant Respondent [Assessment Year : 2010-11] M/S. Acme Cleantech Solutions Vs Addl.Cit, Ltd., C/O-M/S. Rra Taxindia, Range-1 D-28, South Extension, Part-1, New Delhi New Delhi-110049 Pan-Aaeca0914A Appellant Respondent [Assessment Year : 2010-11] Dcit, Vs M/S. Acme Tele Power Ltd. Circle-1(1) [Now, Known As M/S. Acme New Delhi Cleantech Solutions Ltd.] C/O-M/S. Rra Taxindia, D-28, South Extension, Part-1, New Delhi-110049 Pan-Aaeca0914A Appellant Respondent

Section 143(3)Section 144C(13)Section 14ASection 92BSection 92C

necessary evidences relating to the allotment of shares before merger by the erstwhile company and also filed KYC details, financials and tax residency certificates of M/s Jackson Heights. It is further seen that financial statements were directly sent by the company to the AO however, all these facts remained unverified ... necessary verification and accordingly, this issue remitted back to the file to AO for making necessary verification from the financials and tax residency certificate submitted in respect of the company M/s. Jackson Heights Investment Ltd., Mauritius. Accordingly, Ground of appeal No.2 raised by the assessee is partly allowed for statistical

M/S. Acme Cleantech Solutions Ltd., New Delhi vs. DCIT, New Delhi

In the result, appeal of the Revenue is dismissed

ITA 3641/DEL/2017[2011-12]Status: DisposedITAT Delhi20 Nov 2025AY 2011-12

Bench: Shri Sudhir Pareek & Shri Manish Agarwal[Assessment Year : 2011-12] M/S. Acme Cleantech Solutions Vs Dcit, Ltd., C/O-M/S. Rra Taxindia, Circle-1(2) D-28, South Extension, Part-1, New Delhi New Delhi-110049 Pan-Aaeca0914A Appellant Respondent [Assessment Year : 2010-11] M/S. Acme Cleantech Solutions Vs Addl.Cit, Ltd., C/O-M/S. Rra Taxindia, Range-1 D-28, South Extension, Part-1, New Delhi New Delhi-110049 Pan-Aaeca0914A Appellant Respondent [Assessment Year : 2010-11] Dcit, Vs M/S. Acme Tele Power Ltd. Circle-1(1) [Now, Known As M/S. Acme New Delhi Cleantech Solutions Ltd.] C/O-M/S. Rra Taxindia, D-28, South Extension, Part-1, New Delhi-110049 Pan-Aaeca0914A Appellant Respondent

Section 143(3)Section 144C(13)Section 14ASection 92BSection 92C

necessary evidences relating to the allotment of shares before merger by the erstwhile company and also filed KYC details, financials and tax residency certificates of M/s Jackson Heights. It is further seen that financial statements were directly sent by the company to the AO however, all these facts remained unverified ... necessary verification and accordingly, this issue remitted back to the file to AO for making necessary verification from the financials and tax residency certificate submitted in respect of the company M/s. Jackson Heights Investment Ltd., Mauritius. Accordingly, Ground of appeal No.2 raised by the assessee is partly allowed for statistical

M/S. Acme Cleantech Solutions Ltd., New Delhi vs. Addl. CIT, New Delhi

In the result, appeal of the Revenue is dismissed

ITA 4478/DEL/2016[2010-11]Status: DisposedITAT Delhi20 Nov 2025AY 2010-11

Bench: Shri Sudhir Pareek & Shri Manish Agarwal[Assessment Year : 2011-12] M/S. Acme Cleantech Solutions Vs Dcit, Ltd., C/O-M/S. Rra Taxindia, Circle-1(2) D-28, South Extension, Part-1, New Delhi New Delhi-110049 Pan-Aaeca0914A Appellant Respondent [Assessment Year : 2010-11] M/S. Acme Cleantech Solutions Vs Addl.Cit, Ltd., C/O-M/S. Rra Taxindia, Range-1 D-28, South Extension, Part-1, New Delhi New Delhi-110049 Pan-Aaeca0914A Appellant Respondent [Assessment Year : 2010-11] Dcit, Vs M/S. Acme Tele Power Ltd. Circle-1(1) [Now, Known As M/S. Acme New Delhi Cleantech Solutions Ltd.] C/O-M/S. Rra Taxindia, D-28, South Extension, Part-1, New Delhi-110049 Pan-Aaeca0914A Appellant Respondent

Section 143(3)Section 144C(13)Section 14ASection 92BSection 92C

necessary evidences relating to the allotment of shares before merger by the erstwhile company and also filed KYC details, financials and tax residency certificates of M/s Jackson Heights. It is further seen that financial statements were directly sent by the company to the AO however, all these facts remained unverified ... necessary verification and accordingly, this issue remitted back to the file to AO for making necessary verification from the financials and tax residency certificate submitted in respect of the company M/s. Jackson Heights Investment Ltd., Mauritius. Accordingly, Ground of appeal No.2 raised by the assessee is partly allowed for statistical

DCIT, Circle 4(2), New Delhi vs. Blue Jay Finlease Pvt Ltd, New Delhi

Appeal is dismissed

ITA 4416/DEL/2024[2018-19]Status: DisposedITAT Delhi11 Nov 2025AY 2018-19

Bench: Shri Satbeer Singh Godara & Shri Rifaur Rahmanassessment Year: 2018-19 Vs. Blue Jay Finlease Pvt. Ltd, Dcit, Circle-4(2), 26, Kasturba Gandhi Marg, New Delhi Delhi-110001 Pan: Aaacb5215H (Appellant) (Respondent) Assessee By Sh. Rajesh Bansal, Ca Department By Sh. Ajay Kumar Arora, Sr. Dr

Section 143(3)Section 56(2)(vii)Section 56(2)(viib)

Matrix Partners 5. Balance sheet extract as on 31 Dec 2020 6. Bank statement evidencing the investment 7. Tax Residency Certificate 8. PAN number 1. Copy of PAN 2. ITR Acknowledgement for AY 2018-19 2 WaterBridge Ventures - I 3. Bank statement evidencing the investment 4. Net Worth certificate

Argos Holdings Pte. Ltd., Singapore vs. Deputy Commissioner of Income Tax, Circle Int Tax 1(1)(1), Delhi

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

ITA 3633/DEL/2025[2017-18]Status: DisposedITAT Delhi06 Nov 2025AY 2017-18

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.

For Appellant: Shri S.K. Tulsiyan, AdvocateFor Respondent: Shri Saroj Kumar Dubey, CIT DR
Section 144C(5)Section 147Section 148Section 148ASection 151Section 194LSection 1ISection 260Section 6(3)Section 6(3)(ii)

wholly- 07.08.2014 Petitioner in 1 1 & 2-38 owned subsidiary of Ephesus Singapore Holdings Pte. Ltd., Singapore. Admitted fact in both writ petitions. Tax Residency Certificate (TRC) - - 1 39-40 issued by the competent authority of registration under SEBI (FPI) SEBI Regulations, 2014 (Reg. No. 30.10.2014 Registration ... wholly-owned subsidiary of Ephesus Holdings Pte. Ltd., Singapore, and during the relevant period was in possession of a valid Tax Residency Certificate (TRC) issued by the competent authority of Singapore. The Appellant was also duly registered as a Foreign Portfolio Investor (Category III) with the Securities and Exchange Board

Argos Holdings Pte. Ltd., Singapore vs. Deputy Commissioner of Income Tax, Circle Int Tax 1(1)(1), Delhi

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

ITA 3632/DEL/2025[2015-16]Status: DisposedITAT Delhi06 Nov 2025AY 2015-16

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.

For Appellant: Shri S.K. Tulsiyan, AdvocateFor Respondent: Shri Saroj Kumar Dubey, CIT DR
Section 144C(5)Section 147Section 148Section 148ASection 151Section 194LSection 1ISection 260Section 6(3)Section 6(3)(ii)

wholly- 07.08.2014 Petitioner in 1 1 & 2-38 owned subsidiary of Ephesus Singapore Holdings Pte. Ltd., Singapore. Admitted fact in both writ petitions. Tax Residency Certificate (TRC) - - 1 39-40 issued by the competent authority of registration under SEBI (FPI) SEBI Regulations, 2014 (Reg. No. 30.10.2014 Registration ... wholly-owned subsidiary of Ephesus Holdings Pte. Ltd., Singapore, and during the relevant period was in possession of a valid Tax Residency Certificate (TRC) issued by the competent authority of Singapore. The Appellant was also duly registered as a Foreign Portfolio Investor (Category III) with the Securities and Exchange Board

Skechers Sarl, Mumbai vs. The Assistant Commissioner of Income Tax 4(2)(1), Mumbai

In the result the appeal filed by the assessee stands partly

ITA 2028/MUM/2025[2022-23]Status: DisposedITAT Mumbai03 Nov 2025AY 2022-23

Bench: Smt. Beena Pillai () & Smt. Renu Jauhri ()

Section 143(3)Section 144CSection 144C(13)Section 153Section 234BSection 270A

DTAA). 3.5 In the draft assessment order, the Ld.AO proposed to deny beneficial provisions of India-Swiss DTAA on the ground that, the Tax Residency Certificate (TRC') submitted by the Assessee pertains to Korea-Swiss Treaty. 3.6 Further, the Ld.AO proposed to tax the receipt as business income ... hereinafter referred to as the Act), in order to claim benefit of taxation under DTAA being more beneficial, an asscasce has to furnish Tax Residency Certificate (TRC) for the year under consideration. However, in this case during the course of assessment proceedings the assessee had failed to furnish valid

B S R & Associates LLP, Mumbai vs. Principal Commissioner of Income Tax-8, Mumbai

In the result, appeal of the assessee is allowed

ITA 2397/MUM/2025[2018-19]Status: DisposedITAT Mumbai31 Oct 2025AY 2018-19

Bench: Shri Pawan Singh & Shri Girish Agrawal

For Appellant: Shri S. K. Aggarwal, Ajit Kumar Jain
Section 147Section 148Section 263Section 9(1)(vii)

subject to tax in India and consequently, there was no requirement of tax withholding therefrom. e Copies of invoices, declaration, agreements/Letter of engagements, Tax residency Certificates and Form 15CA/Form 15CB. c. The FAO, in the reassessment order dated 09 March 2023 [See Point 11...pages

Snc Lavalin Inc., Delhi vs. The Assistant Commissioner of Income Tax/ Circle International Tax 3(1)(2), Delhi

In the result, the Appeal of the assessee is allowed, the Stay Application of the assessee is dismissed as infructuous

ITA 1760/DEL/2025[2022-23]Status: DisposedITAT Delhi30 Oct 2025AY 2022-23

Bench: Shri Vikas Awasthy & Shri Brajesh Kumar Singh

Section 143(3)Section 144C(1)

during the year was engaged in the business of rendering consultancy, design and engineering services to various clients. The company submitted its TRC (Tax Residency Certificate) issued by the authority of Canada. During the course of assessment proceedings, the assessee submitted that it has project offices in India for execution

Fullerton Financial Holdings Pte. Ltd., Singapore vs. The Assistant Commissioner of Income-Tax - (International Taxation), Circle 2(3)(1) - Mumbai, Mumbai

ITA 1137/MUM/2025[2022-23]Status: DisposedITAT Mumbai28 Oct 2025AY 2022-23

Bench: Smt. Beena Pillai () & Smt. Renu Jauhri ()

Section 143(2)Section 143(3)Section 144CSection 144C(1)Section 144C(13)Section 144C(5)Section 153

been assessed to tax therein. The Appellant has furnished substantial documentation evidencing its genuine business presence and continuous business operations in Singapore, including; • Tax Residency Certificate (TRC) issued by the Singapore tax authority (refer to Page Nos. 11 and 12 of the Factual PB), • Profile and credentials of the Board

Anuj Choudhary, Bhopal vs. It0, 1(1), Bhopal

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

ITA 204/IND/2025[2018-19]Status: DisposedITAT Indore23 Oct 2025AY 2018-19

Bench: Dr. Manish Borad & Shri Paresh M Joshianuj Choudhary, Income Tax Officer 1(1), Mig 184, Bhopal Geetanjali Complex, Vs. Bhopal (Appellant / Assessee) (Respondent/ Revenue) Pan: Aqepc6217D Assessee By Shri Balaji.V, Ar Revenue By Ms. Ila Parmar, Cit-Dr With Shri Nihar Sahu Date Of Hearing 22.10.2025 Date Of Pronouncement 23.10.2025 O R D E R

Section 143(1)Section 192Section 90

Rs.19,94,082/- on the total amount paid/credited at Rs.64,91,670/-. The assessee has also enclosed a copy of tax residency certificate issued by the Singapore Tax Authorities certifying that the assessee was a resident in Singapore for income tax purposes for calendar year 2017-2018. These facts indicates ... given situation where the assessee has declared himself as resident in the ITR and on the other hand he holds a Tax Residency Certificate of Singapore, we find that the issue deserves to be examined by the Ld. Assessing Officer and if the alleged claim of the assessee is found