AYESA INGENIERIA Y ARQUITECTURA S.A.,NOIDA vs. ACIT INTL. TAXATION, GURGAON
In the result, appeal of the assessee is allowed
ITA 2174/DEL/2023[2021-22]Status: DisposedITAT Delhi08 Apr 2024AY 2021-22
Bench: Shri G.S. Pannu, Hon’Ble & Ms. Astha Chandra
For Appellant: Shri Vivek Sarin, AdvocateFor Respondent: Shri Vizay B. Vasanta, CIT-DR
Section 143(3)Section 192BSection 195Section 201Section 40Section 7(3)
circumstances of the case, the Ld. AO erred in law in making addition of Rs. 1,83,71,951/- by applying provisions of section 7(3) of DTAA between India and Spain which is devoid of facts and merits of the case, hence hit addition made is liable ... circumstances of the case, the Ld. AO erred in law in making addition of Rs. 2,53,00,714/ by applying provisions of section 7(3) of DTAA between India and Spain which is devoid of facts and merits of the case, hence addition made is liable to be deleted