“beneficial owner”

Norwest Venture Partners X - Mauritius, Mauritius vs. DCIT Circle Intl. Taxation 2(2)(2), New Delhi

Bench: Shri Saktijit Dey & Shri Pradip Kumar Kedia[Assessment Year: 2020-21]

conclude that the assessee is a shell or conduit company. He submitted, though, the Assessing Officer has held that parent company in USA is beneficial owner of the capital gain, however, under Article 13 of India-Mauritius tax treaty, there is no concept of beneficial ownership, unlike, tax treaty

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

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

reason of his domicile, residence, place of management or any other criterion of similar nature; - a person who, being recipient of payments, is the beneficial owner of the payments; ITA Nos. 2239,884, 885 & 2240/Del/2023 UK Grid Solutions Ltd - a person who is a legitimate resident of the contracting State ... Energy UK Ltd. receives all income and pays all expenditure of the assessee company. It is evident that the assessee company is not a beneficial owner of any income earned by it from its business activities as it is practically fiscally transparent even if the legal form suggests otherwise

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

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

reason of his domicile, residence, place of management or any other criterion of similar nature; - a person who, being recipient of payments, is the beneficial owner of the payments; ITA Nos. 2239,884, 885 & 2240/Del/2023 UK Grid Solutions Ltd - a person who is a legitimate resident of the contracting State ... Energy UK Ltd. receives all income and pays all expenditure of the assessee company. It is evident that the assessee company is not a beneficial owner of any income earned by it from its business activities as it is practically fiscally transparent even if the legal form suggests otherwise

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

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

reason of his domicile, residence, place of management or any other criterion of similar nature; - a person who, being recipient of payments, is the beneficial owner of the payments; ITA Nos. 2239,884, 885 & 2240/Del/2023 UK Grid Solutions Ltd - a person who is a legitimate resident of the contracting State ... Energy UK Ltd. receives all income and pays all expenditure of the assessee company. It is evident that the assessee company is not a beneficial owner of any income earned by it from its business activities as it is practically fiscally transparent even if the legal form suggests otherwise

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

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

reason of his domicile, residence, place of management or any other criterion of similar nature; - a person who, being recipient of payments, is the beneficial owner of the payments; ITA Nos. 2239,884, 885 & 2240/Del/2023 UK Grid Solutions Ltd - a person who is a legitimate resident of the contracting State ... Energy UK Ltd. receives all income and pays all expenditure of the assessee company. It is evident that the assessee company is not a beneficial owner of any income earned by it from its business activities as it is practically fiscally transparent even if the legal form suggests otherwise

Ambey Capital Pvt. Ltd., Delhi vs. DCIT, New Delhi

In the result, the appeal of the assessee is allowed

Bench: Shri M. Balaganesh & Shri Yogesh Kumar Usambey Capital Pvt. Ltd, Vs. Dcit, G-2, Ambey House, 34/1, East Circle-2(2), Punjabi Bagh, Delhi New Delhi (Appellant) (Respondent) Pan: Aabct6631J

held that expression “by way of advance or loan” which a shareholder enjoys simply on account of being a person who is beneficial owner of shareholding not less than 10% of voting power, but if such loan or advance is given to such shareholder as Ambey Capital

Superb Mind Holding Ltd., New Delhi vs. ACIT Circle Int Tax 3(1)(2), New Delhi

In the result, appeal of the assessee is allowed

Bench: Shri G.S. Pannu, Hon’Ble & Shri Challa Nagendra Prasadआ.अ.सं/.I.T.A No.1568/Del/2022 िनधा"रणवष"/Assessment Year: 2018-19

without any commercial substance. Tax Department, in such a situation, notwithstanding the fact that the Mauritian company is required to be treated as the beneficial owner of the shares under Circular No. 789 and the Treaty is entitled to took at the entire transaction of sale as a whole ... assessee that such authorization was given as he was the son of Mr. Deepak Seth only proves that Mr. Deepak Seth is the beneficial owner who ultimately owns/exercises ultimate effective control over the assessee company and M/s Pearl Retail Solutions Private Limited. 2.15 Further, no expense relating to remuneration

Natasha Kohli, New Delhi vs. ACIT Central Circle-8, New Delhi

In the result, appeal of the assessee stands partly allowed for statistical purposes

Bench: Shri Narendra Kumar Billaiya & Shri Kul Bharatr Assessment Year: 2014-15

information was received from FIU in the investigation wing regarding foreign account of the assessee. Also it was observed that the assessee is a beneficial owner of said account from FT & TR division of CBDT. 9. The assessee filed a rejoinder to the remand report (PB Pg. 57-58) vide ... issue of the notice u/s 10(1) dated 27.06.2018 in the case of the assessee are actually not held by the assessee as the beneficial owner but are apparently held by Sh. Mon Mohan Kohli as the beneficial owner whose case proceedings are ongoing u/s 10(1)..." It was also