“Section 163(1)”

KISHORE BHAGWANDAS RAMNANI,MUMBAI vs. INTERNATIONAL TAXATION WARD-4(1)(1), MUMBAI

In the result, the appeal of the assessee is allowed

Bench: Shri Amit Shukla & Shri Amarjit Singh, Kishore Bhagwandas Vs. Income Tax Officer-4(1)(1) Ramnani, B-406, Plot No. Air India Building, 442/444, Simla House Off Mumbai – 400021 Ld. Ruparel Marg, Parsi Mumbai – 400026 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No:Bcypr3697F Appellant .. Respondent

Appellant purporting to treat the said CA. Ms. Priyanka Jain as the 'agent of the Appellant for the purpose of section 163(1) of the Act. P a g e | 2 Kishore Bhagwandas Ramnani Vs. ITO-4(1)(1) 3. Without prejudice to the above, the Dispute Resolution Panel erred

DCIT, CC-2(4), MUMBAI vs. KEYSTONE REALTORS P LTD., AS REPRESENTATIVE ASSESSEE OF M/S. MAUSMI VENTURES LTD.,, MUMBAI

Appeal of the Revenue is dismissed

Bench: Shri Vikas Awasthy & Shri Gagan Goyalआअसं.88/मुं/ 2023 से 90/मुं/ 2023 ("न.व.2011-12 से 2013-14)

submitted that the assessee has been treated as representative assessee of M/s. Mausmi Ventures Ltd.( in short ‘MVL’) in terms of section 163(1) of the Income Tax Act, 1961 [in short ‘the Act’], however, no order u/s. 163 of the Act was passed by the Assessing Officer holding

DCIT, CC-2(4), MUMBAI vs. KEYSTONE REALTORS P LTD., AS REPRESENTATIVE ASSESSEE OF M/S. MAUSMI VENTURES LTD.,, MUMBAI

Appeal of the Revenue is dismissed

Bench: Shri Vikas Awasthy & Shri Gagan Goyalआअसं.88/मुं/ 2023 से 90/मुं/ 2023 ("न.व.2011-12 से 2013-14)

submitted that the assessee has been treated as representative assessee of M/s. Mausmi Ventures Ltd.( in short ‘MVL’) in terms of section 163(1) of the Income Tax Act, 1961 [in short ‘the Act’], however, no order u/s. 163 of the Act was passed by the Assessing Officer holding

DCIT, CC-2(4), MUMBAI vs. KEYSTONE REALTORS P LTD AS REPRESENTATIVE ASSESSEE OF M/S. MAUSMI VENTURES LTD.), MUMBAI

Appeal of the Revenue is dismissed

Bench: Shri Vikas Awasthy & Shri Gagan Goyalआअसं.88/मुं/ 2023 से 90/मुं/ 2023 ("न.व.2011-12 से 2013-14)

submitted that the assessee has been treated as representative assessee of M/s. Mausmi Ventures Ltd.( in short ‘MVL’) in terms of section 163(1) of the Income Tax Act, 1961 [in short ‘the Act’], however, no order u/s. 163 of the Act was passed by the Assessing Officer holding

DEPUTY COMMISSIONER OF INCOME TAX (IT)-3(2)(1), MUMBAI vs. M/S MARRIOTT INTERNATIONAL DESIGN & CONSTRUCTION SERVICES INC., MUMBAI

In the result the appeal filed by the Assessing Officer is thus dismissed

Bench: Shri Amit Shukla, Hon'Ble & Shri S. Rifaur Rahman, Hon'Bledcit (It) – 3(2)(1) V. M/S. Marriott International Design Room No. 1632, 16Th Floor & Construction Services Inc., Air India Building, Nariman Point C/O. Marriot Hotels India Pvt. Ltd., Mumbai – 400 021 303A, 304, Fulcrum B-Wing, Hiranandani Business Park Mumbai, Sahar Road Andheri (E) - 400099 Pan: Aagcm5401Q (Appellant) (Respondent) C.O. No. 01/Mum/2023 [Arising Out Of Ita No. 2977/Mum/2022 (A.Y: 2018-19)] M/S. Marriott International Design V. Dcit (It) – 3(2)(1) & Construction Services Inc., Room No. 1632, 16Th Floor C/O. Marriot Hotels India Pvt. Ltd., Air India Building 303A, 304, Fulcrum Nariman Point B-Wing, Hiranandani Business Park Mumbai – 400 021 Mumbai, Sahar Road Andheri (E) - 400099 Pan: Aagcm5401Q (Appellant) (Respondent) Assessee Represented By : Shri Paras Savla Department Represented By : Shri Kunal Haver

appeal, the Appellate Assistant Commissioner held that even if the assessee company was to be treated as an agent within the meaning of section 163(1), there was no business connection within the meaning of section 9(1) of the Act so the income accruing to the non resident foreign

SUKHPAL SINGH AHLUWALIA,MUMBAI vs. ITO(IT)WARD1(1)(1), MUMBAI

In the result, the appeal filed by the assessee is allowed for statistical purpose

Bench: Shri M. Balaganesh, Am & Ms. Kavitha Rajagopal, Jm Sukhpal Singh Ahluwalia Ito (It), Ward (1)(1) 6/24, Milan Building, 87, Tardeo Road, Mumbai Opp. Tardeo A. C. Market, Vs. Mumbai-400 034

assessee has filed Form 35A with the signature of the assessee’s authorized representative who was not the agent within the meaning of section 163(1) of the Act, pertaining to Assessment Year (A.Y. for short) 2019-20. 2. The assessee has challenged the order of DRP dated 15.06.2022, where ... Shri Rashmikant C. Modi, Chartered Accountant who then stated that they were not agent of the assessee within the meaning of provision of section 163(1) of the Act. 4. By considering the above submission, the ld. DRP held that as Form No. 35A ought to be filed

DCIT (IT) 3(2) (1) , MUMBAI vs. M/S. MARRIOTT INTERNATIONAL DESIGN & CONSTRUCTION SERVICES INC., MUMBAI

In the result the appeal filed by the Assessing Officer is thus dismissed

appeal, the Appellate Assistant Commissioner held that even if the assessee company was to be treated as an agent within the meaning of section 163(1), there was no business connection within the meaning of section 9(1) of the Act so the income accruing to the non resident foreign

MIZUHO BANK LTD,MUMBAI vs. DCIT (IT) 3(2)(2), MUMBAI

Bench: Shri Pramod Kumar & Shri Sandeep Singh Karhail

India and accordingly, taxable in India. The AO further held that the branch office is representative assessee/agent of the head office as per section 163(1)(c) of the Act. Accordingly, the AO taxed the interest income @ 10% of gross amount under Art 11(2)(a) of the India Japan

MIZUHO BANK LTD,MUMBAI vs. DDIT (IT) 4(1), MUMBAI

Bench: Shri Pramod Kumar & Shri Sandeep Singh Karhail

India and accordingly, taxable in India. The AO further held that the branch office is representative assessee/agent of the head office as per section 163(1)(c) of the Act. Accordingly, the AO taxed the interest income @ 10% of gross amount under Art 11(2)(a) of the India Japan

DCIT (IT) 3(2)(2), MUMBAI vs. MIZUHO CORPORATE BANK MAKER, MUMBAI

Bench: Shri Pramod Kumar & Shri Sandeep Singh Karhail

India and accordingly, taxable in India. The AO further held that the branch office is representative assessee/agent of the head office as per section 163(1)(c) of the Act. Accordingly, the AO taxed the interest income @ 10% of gross amount under Art 11(2)(a) of the India Japan

DCIT (IT) 3(2)(2), MUMBAI vs. MIZUHO CORPORATE BANK MAKER, MUMBAI

Bench: Shri Pramod Kumar & Shri Sandeep Singh Karhail

India and accordingly, taxable in India. The AO further held that the branch office is representative assessee/agent of the head office as per section 163(1)(c) of the Act. Accordingly, the AO taxed the interest income @ 10% of gross amount under Art 11(2)(a) of the India Japan

DCIT (IT) -3(2) (2), MUMBAI vs. M/S. MARRIOTT INTERNATION SERVICESAL DESIGN & CONSTRUCTION, MUMBAI

In the result the appeal filed by the Assessing Officer is thus dismissed

appeal, the Appellate Assistant Commissioner held that even if the assessee company was to be treated as an agent within the meaning of section 163(1), there was no business connection within the meaning of section 9(1) of the Act so the income accruing to the non resident foreign

DCIT (IT) -3(2) (2), MUMBAI vs. M/S. MARRIOTT INTERNATIONAL DESIGN & CONSTRUCTION SERVICES, MUMBAI

In the result the appeal filed by the Assessing Officer is thus dismissed

appeal, the Appellate Assistant Commissioner held that even if the assessee company was to be treated as an agent within the meaning of section 163(1), there was no business connection within the meaning of section 9(1) of the Act so the income accruing to the non resident foreign

DCIT (IT) -3(2) (2) , MUMBAI vs. M/S. MARRIOTT INTERNATIONAL DESIGN & CONSTRUCTION SERVICES, MUMBAI

In the result the appeal filed by the Assessing Officer is thus dismissed

appeal, the Appellate Assistant Commissioner held that even if the assessee company was to be treated as an agent within the meaning of section 163(1), there was no business connection within the meaning of section 9(1) of the Act so the income accruing to the non resident foreign