“Section 9(1)(v)(c)”

AUSTRALIA AND NEW ZEALAND BANKING GROUP LTD.,MUMBAI vs. DCIT (IT)-1(1)(2), MUMBAI

In the result, appeal of the assessee is allowed

Bench: Shri Saktijit Dey, Hon'Ble & Shri Girish Agrawalassessment Year: 2014-15 Australia & New Zealand Deputy Commissioner Of Banking Group Ltd. Income-Tax – 1(1)(2), Unit A, Sixth Floor, Mumbai Cnergy Centre, Appasaheb Marathe Marg, Vs. Prabhadevi, Mumbai – 400 025 (Pan : Aaica3008P) (Appellant) (Respondent) Present For: Assessee : Shri Madhur Agrawal, Advocate Revenue : Shri Annavaram K., Sr. Dr Date Of Hearing : 14.11.2025 Date Of Pronouncement : 12.02.2026 O R D E R Per Girish Agrawal: This Appeal Filed By The Assessee Is Against The Final Assessment Order Passed Pursuant To The Directions Of The Dispute Resolution Panel-1, Mumbai, (Drp) Vide Order Dated 04.09.2018 U/S. 144C(5) Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”), For Assessment Year 2014-15. 2. Grounds Taken By The Assessee Are Reproduced As Under: Ground 1: Determination Of The Arm'S Length Price (Alp) Of The International Transaction Relating To Processing Fees Received On Account Of Guarantees Issued To Indian Companies Based On Counter-Guarantee From Overseas Branches

nature of 'receipt from self.’ Ld. Assessing Officer, in the draft assessment order dated 26.12.2017, referred to the provisions of section 9(1)(v)(c) of the Act and held that the said section provides for a source rule for taxation and that it does not make any distinction about

CREDIT AGRICOLE CORPORATE AND INVESTMENT BANK,MUMBAI vs. THE DY-CIT (INT. TAXATION)-2(1)(1), MUMBAI

Accordingly these grounds are dismissed as not pressed

Bench: Smt Beena Pillai, Jm & Ms Padmavathy S, Am I.T. (Tp) A. No. 1479/Mum/2015 (Assessment Year: 2010-11) Credit Agricole Corporate & Dcit (International Taxation)- Investment Bank (Formerly 2(1)(1), 1St Floor, Room No. 136, Known As ‘Calyon Bank’) Vs. 11Th Floor, Hoechst House, Scindia House, N.M. Marg, Nariman Point, Mumbai-400021. Ballard Pier, Mumbai-400038. Pan: Aaccc3872B Appellant) : Respondent)

IN THE INCOME TAX APPELLATE TRIBUNAL “I” BENCH, MUMBAI BEFORE SMT BEENA PILLAI, JM & MS PADMAVATHY S, AM I.T. (TP

CREDIT AGRICOLE CORPORATE & INVESTMENT BANK,MUMBAI vs. THE DY.CIT OF INCOME TAX (INTERNATIONSL TAXATION) -2(1) (1) , MUMBAI

Accordingly these grounds are dismissed as not pressed

Bench: Smt Beena Pillai, Jm & Ms Padmavathy S, Am I.T. (Tp) A. No. 1479/Mum/2015 (Assessment Year: 2010-11) Credit Agricole Corporate & Dcit (International Taxation)- Investment Bank (Formerly 2(1)(1), 1St Floor, Room No. 136, Known As ‘Calyon Bank’) Vs. 11Th Floor, Hoechst House, Scindia House, N.M. Marg, Nariman Point, Mumbai-400021. Ballard Pier, Mumbai-400038. Pan: Aaccc3872B Appellant) : Respondent)

IN THE INCOME TAX APPELLATE TRIBUNAL “I” BENCH, MUMBAI BEFORE SMT BEENA PILLAI, JM & MS PADMAVATHY S, AM I.T. (TP

CREDIT AGRICOLE CORPORATE & INVESTMENT BANK,MUMBAI vs. THE JT CIT (INTERNATIONAL TAXATIONA), MUMBAI

Accordingly these grounds are dismissed as not pressed

{ "clean_text": "IN THE INCOME TAX APPELLATE TRIBUNAL\n“I” BENCH, MUMBAI\nBEFORE SMT BEENA PILLAI, JM & MS PADMAVATHY S

CREDIT AGRICOLE CORPORATE AND INVESTMENT BANK,MUMBAI vs. ACIT (IT) 2 (1)(1), MUMBAI

Accordingly these grounds are dismissed as not pressed

{ "clean_text": "IN THE INCOME TAX APPELLATE TRIBUNAL\n“I” BENCH, MUMBAI\nBEFORE SMT BEENA PILLAI, JM &\nMS PADMAVATHY S

CREDIT AGRICOLE CORPORATE AND INVESTMENT BANK,MUMBAI vs. DCIT (IT) 2(1)(1), MUMBAI

Accordingly these grounds are dismissed as not pressed

{ "clean_text": "IN THE INCOME TAX APPELLATE TRIBUNAL\n“I” BENCH, MUMBAI\nBEFORE SMT BEENA PILLAI, JM &\nMS PADMAVATHY S

CREDIT AGRICOLE CORPORATE AND INVESTMENT BANK,MUMBAI vs. DCIT (IT) 2(1)(1), MUMBAI

Accordingly these grounds are dismissed as not pressed

{ "clean_text": "IN THE INCOME TAX APPELLATE TRIBUNAL\n“I” BENCH, MUMBAI\nBEFORE SMT BEENA PILLAI, JM &\nMS PADMAVATHY S

DCIT (IT) 2(1)(1), MUMBAI vs. CREDIT AGRICOLE CORPORATE AND INVESTMENT BANK, MUMBAI

Accordingly these grounds are dismissed as not pressed

{ "clean_text": "IN THE INCOME TAX APPELLATE TRIBUNAL\n“I” BENCH, MUMBAI\nBEFORE SMT BEENA PILLAI, JM &\nMS PADMAVATHY S

ADIT (IT) 1(2), MUMBAI vs. CREDIT AGRICOLE CORPORATE AND INVESTMENT BANK, MUMBAI

Accordingly these grounds are dismissed as not pressed

Bench: Smt Beena Pillai, Jm & Ms Padmavathy S, Am I.T. (Tp) A. No. 1479/Mum/2015 (Assessment Year: 2010-11) Credit Agricole Corporate & Dcit (International Taxation)- Investment Bank (Formerly 2(1)(1), 1St Floor, Room No. 136, Known As ‘Calyon Bank’) Vs. 11Th Floor, Hoechst House, Scindia House, N.M. Marg, Nariman Point, Mumbai-400021. Ballard Pier, Mumbai-400038. Pan: Aaccc3872B Appellant) : Respondent)

IN THE INCOME TAX APPELLATE TRIBUNAL “I” BENCH, MUMBAI BEFORE SMT BEENA PILLAI, JM & MS PADMAVATHY S, AM I.T. (TP

THE HONGKONG AND SHANGHAI BANKING CORPORATION LIMITED ,MUMBAI vs. THE DEPUTY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION)-2(2)(2), MUMBAI

1335/Mum/2024\ninterest becomes payable by the PE, a non-resident for the purposes of the Act,\nthe provisions of section 9(1)(v)(c) become attracted and the source rule for\ninterest income becomes applicable for charging of this interest as income\ndeemed to accrue or arise in India ... nGuidelines. The difference comes to Rs. 1,16,69,304/- for AY 2013-14.\nAs per provisions of section 9(1)(v) (c) of the Act, the moment interest\nbecomes payable by the PE, a non-resident for the purposes of the Act, the\nsource rule for interest income becomes

THE HONGKONG AND SHANGHAI BANKING CORPORATION LIMITED INDIA BRANCHES ,MUMBAI vs. THE DEPUTY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION)-2(2)(2), MUMBAI

1335/Mum/2024\ninterest becomes payable by the PE, a non-resident for the purposes of the Act,\nthe provisions of section 9(1)(v)(c) become attracted and the source rule for\ninterest income becomes applicable for charging of this interest as income\ndeemed to accrue or arise in India ... nGuidelines. The difference comes to Rs. 1,16,69,304/- for AY 2013-14.\nAs per provisions of section 9(1)(v) (c) of the Act, the moment interest\nbecomes payable by the PE, a non-resident for the purposes of the Act, the\nsource rule for interest income becomes

THE HONGKONG AND SHANGHAI BANKING CORPORATION LIMITED -INDIA BRANCHES ,MUMBAI vs. THE DEPUTY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION)-2(2)(2), MUMBAI

Thus, the moment\ncopy\ninterest becomes payable by the PE, a non-resident for the purposes of the Act,\nthe provisions of section 9(1)(v)(c) become attracted and the source rule for\ninterest income becomes applicable for charging of this interest as income\ndeemed to accrue or arise ... nGuidelines. The difference comes to Rs. 1,16,69,304/- for AY 2013-14.\nAs per provisions of section 9(1)(v) (c) of the Act, the moment interest\nbecomes payable by the PE, a non-resident for the purposes of the Act, the\nsource rule for interest income becomes

DCIT(IT)-2(2)(2), NARIMAN POINT vs. THE HONGKONG AND SHANGHAI BANKING CORPORATION LTD, BANDRA

1335/Mum/2024\ninterest becomes payable by the PE, a non-resident for the purposes of the Act,\nthe provisions of section 9(1)(v)(c) become attracted and the source rule for\ninterest income becomes applicable for charging of this interest as income\ndeemed to accrue or arise in India ... nGuidelines. The difference comes to Rs. 1,16,69,304/- for AY 2013-14.\nAs per provisions of section 9(1)(v)(c) of the Act, the moment interest\nbecomes payable by the PE, a non-resident for the purposes of the Act, the\nsource rule for interest income becomes

DCIT(IT) - 2(2)(2), AIR INDIA BUILDING vs. THE HONGKONG AND SHANGHAI BANKING CORPORATION LTD, BANDRA

1335/Mum/2024\ninterest becomes payable by the PE, a non-resident for the purposes of the Act,\nthe provisions of section 9(1)(v)(c) become attracted and the source rule for\ninterest income becomes applicable for charging of this interest as income\ndeemed to accrue or arise in India ... nGuidelines. The difference comes to Rs. 1,16,69,304/- for AY 2013-14.\nAs per provisions of section 9(1)(v)(c) of the Act, the moment interest\nbecomes payable by the PE, a non-resident for the purposes of the Act, the\nsource rule for interest income becomes

DCIT(IT)-2(2)(2), AIR INDIA BUILDING vs. THE HONGKONG AND SHANGHAI BANKING CORPORATION LTD, BANDRA

In the result, appeals by the revenue are accordingly dismissed\nand those by the assessee are allowed

1335/Mum/2024\ninterest becomes payable by the PE, a non-resident for the purposes of the Act,\nthe provisions of section 9(1)(v)(c) become attracted and the source rule for\ninterest income becomes applicable for charging of this interest as income\ndeemed to accrue or arise in India ... nGuidelines. The difference comes to Rs. 1,16,69,304/- for AY 2013-14.\nAs per provisions of section 9(1)(v) (c) of the Act, the moment interest\nbecomes payable by the PE, a non-resident for the purposes of the Act, the\nsource rule for interest income becomes

THE HONGKONG AND SHANGHAI BANKING CORPORATION LTD,MUMBAI vs. ADDL DIT (IT) -3, MUMBAI

In the result, the captioned appeals by the assessee are partly allowed and that of the revenue are partly allowed

Bench: Shri Narendra Kumar Billaiya, Hon'Ble & Shri Raj Kumar Chauhan, Hon'Ble

IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “H”, MUMBAI BEFORE SHRI NARENDRA KUMAR BILLAIYA, HON'BLE ACCOUNTANT MEMBER AND

DCIT (IT) 2(2)(2), MUMBAI vs. THE HONGKONG AND SHANGHAI BANKING CORP LTD, MUMBAI

In the result, the captioned appeals by the assessee are partly allowed and that of the revenue are partly allowed

Bench: Shri Narendra Kumar Billaiya, Hon'Ble & Shri Raj Kumar Chauhan, Hon'Ble

IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “H”, MUMBAI BEFORE SHRI NARENDRA KUMAR BILLAIYA, HON'BLE ACCOUNTANT MEMBER AND