“double taxation”

MiscellaneousGeneralGeneral4,703 judgments

The decision most relied on for double taxation is DIT v. New Skies Satellite BV (382 ITR 114), cited in 325 judgments on BharatTax.

Leading authorities on double taxation

DIT v. New Skies Satellite BV

382 ITR 114 · 2016 · High Court

325

citing judgments

An amendment to the Income Tax Act, such as the Finance Act, 2012 amendment to Section 9(1)(vi) defining royalty, does not automatically override or alter the definition of 'royalty' as provided in a Double Taxation Avoidance Agreement (DTAA) unless the DTAA itself is bilaterally amended. The definition of royalty in a DTAA remains unaffected by unilateral changes to domestic law.

CIT v. Siemens Aktiongesellschaft

310 ITR 320 · 2009 · High Court

259

citing judgments

Reimbursements of actual expenses without any profit element are not taxable income. Additionally, mere amendments to the Income-tax Act do not override the provisions of Double Taxation Avoidance Agreements (DTAAs).

Transmission Corporation of Andhra Pradesh v. CIT

239 ITR 587 · 1999 · Supreme Court

243

citing judgments

The Supreme Court lays down principles for deducting tax at source (TDS) under Section 195 on payments to non-residents, including aspects of income deemed taxable in India and the application of Double Taxation Avoidance Agreements (DTAAs) under Section 90.

Raymond Ltd. v. Dy. CIT

86 ITD 791 · 2003 · ITAT

154

citing judgments

For services to qualify as 'Fees for Technical Services' or 'Fees for Included Services' under Double Taxation Avoidance Agreements (DTAAs), they must 'make available' technical knowledge, experience, skill, or processes to the recipient, enabling them to apply such expertise independently.

CIT v. Visakhapatnam Port Trust

144 ITR 146 · 1983 · High Court

124

citing judgments

Sections 4 and 5 of the Income Tax Act, which define total income and chargeability, are subject to Section 90, meaning that Double Taxation Avoidance Agreements (DTAAs) override the Act's provisions in case of a conflict.

Assessing Officer (International Taxation) v. Nestle SA

458 ITR 756 · 2023 · Supreme Court

122

citing judgments

The benefit of a Most Favoured Nation (MFN) clause in a Double Taxation Avoidance Agreement (DTAA) is available only upon notification by the Government. A notification under section 90(1) is a necessary and mandatory condition for giving effect to a DTAA or any protocol that alters existing law.

Ms. Brinda Ramakrishna v. ITO

135 Taxmann.com 358 · 2022 · ITAT

109

citing judgments

The filing of Form 67 for claiming Foreign Tax Credit (FTC) is a directory requirement, not mandatory. Rule 128(9) does not provide for disallowance of FTC due to delay in filing this form. Double Taxation Avoidance Agreements (DTAAs) override domestic law.

CIT v. Havells India Ltd.

352 ITR 376 · 2013 · High Court

citing judgments

For royalty income, especially in the context of Double Taxation Avoidance Agreements (DTAA), the 'source of income' is the determinative factor for taxability, rather than merely the 'source of receipt'.

Judgments citing double taxation

Nirman Sonestaa Developers, Bengaluru vs. Deputy Commissioner of Income Tax, Circle- 4(1)(1), Bangalore

In the result, the appeal by the assessee is dismissed

ITA 1536/BANG/2025[2018-19]Status: DisposedITAT Bangalore14 Nov 2025AY 2018-19

Bench: Shri Prashant Maharishi & Shri Sandeep Singh Karhailassessment Year: 2018-19

For Appellant: NoneFor Respondent: Sri Subramanian, D.R

Section 142(1)Section 143(2)Section 250Section 37Section 37(1)

expenditure being directly connected with the earning of taxable income is allowable u/s 37(1). The action of the CIT(A) causes double taxation of the same source of income – revenue taxed, but related cost disallowed. 6. The appellant relies on the following judicial precedents; RDB Industries Ltd. v. ACIT

Ankit Garg, Delhi vs. ITO, Ward-35(3), Delhi

In the result, the appeal of the assessee is allowed

ITA 5507/DEL/2024[2017-18]Status: DisposedITAT Delhi14 Nov 2025AY 2017-18

Bench: Shris.Rifaur Rahman & Shri Anubhav Sharmaankit Garg, Vs. Ito, Ward 35 (3), L – 153, Shastri Nagar, New Delhi. Delhi – 110 052. (Pan : Amhpg1493N) (Appellant) (Respondent) Assessee By :Shri V.K. Sabharwal, Advocate Shri Rajiv Kumar, Advocate Revenue By : Shri Ajay Kumar Arora, Sr. Dr Date Of Hearing : 28.10.2025 Date Of Order : 14.11.2025 Order Per S. Rifaur Rahman: 1. The Assessee Has Filed Appeal Against The Order Of The Learned Commissioner Of Income-Tax (Appeals)/National Faceless Appeal Centre (Nfac), Delhi [“Ld. Cit(A)”, For Short] Dated 03.10.2024For The Assessment Year 2017-18. 2. Brief Facts Of The Case Are, The Assessee Is An Individual, Engaged In The Business Of Manufacturing, Trading, Sales Of Socks, Fabrics & Hosiery Etc. The Assessee Filed His Return Of Income On 25.01.2018 For A.Y. 2017-18

For Appellant: Shri V.K. Sabharwal, AdvocateFor Respondent: Shri Ajay Kumar Arora, Sr. DR

Section 143(2)Section 143(3)Section 40Section 68

reported. • Profits from all sales, including those represented by the cash deposits, have already been assessed to tax; any further addition leads to impermissible double taxation. • There is complete consistency and reconciliation among the stock, VAT records, and creditors' ledgers; no discrepancies or adverse findings were noted during assessment ... mere presence of cash deposits in the bank, matching with regular business turnover and supported by documentary evidence, does not justify addition. Further, double taxation of income already offered and assessed is illegal and unsustainable." 7. Further with regard to the issue of cash sales could not be treated

Rakhi Agarwal, Gwalior vs. ACIT, Gwalior

In the result, the appeal of the assessee is allowed

ITA 249/AGR/2024[201718]Status: DisposedITAT Agra13 Nov 2025

Bench: Shri M. Balaganesh(Through Virtual Hearing) Rakhi Agarwal, Vs. Acit, Krishna Bhawan Opp, Gwalior Morena Wala Halwai, Daulat Ganj Lashkar, Mp (Appellant) (Respondent) Pan: Aeapa9383A Assessee By : Shri Rajesh Malhotra, Ca Revenue By: Shri Anil Kumar, Sr. Dr Date Of Hearing 18/08/2025 Date Of Pronouncement 13/11/2025

For Appellant: Shri Rajesh Malhotra, CAFor Respondent: Shri Anil Kumar, Sr. DR

Section 143(3)

accepted, then the same should be reduced from the return of income of Rs. 23,70,830/- in order to avoid double taxation. This is not done by the revenue in the instant case. Hence, a sum of Rs. 7,22,738/- being available to the assessee as a cash

Krishna Prabhas Agro Oils Private Limited, Maredubaka vs. Assisstant Commissioner of Income Tax, Kakinada

In the result, we herein, in terms of our aforesaid observations, set aside the CIT(A) order and vacate the addition of Rs

ITA 546/VIZ/2025[2017-2018]Status: DisposedITAT Visakhapatnam12 Nov 2025AY 2017-2018

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.546/Viz/2025 ("नधा"रण वष"/Assessment Year: 2017-18) Krishna Prabhas Agro Oils Vs. Assistant Commissioner Private Limited, Of Income Tax, Maredubaka, Kakinada. Kakinada. Pan: Aaics2638B (Appellant) (Respondent) "नधा"रती "वारा/Assessee By: Mrs. Hema Latha. K, Ca (Hybrid Hearing) राज" व "वारा/Revenue By: Dr. Aparna Villuri, Sr. Ar सुनवाई क" तार"ख/Date Of 10/11/2025 Hearing: घोषणा क" तार"ख/Date Of 12/11/2025 Pronouncement: आदेश / Order Per. Ravish Sood, J.M:

For Appellant: Mrs. Hema Latha. K, CAFor Respondent: Dr. Aparna Villuri, Sr. AR

Section 143(1)Section 147Section 148Section 250Section 68

erred in re-characterizing a part of the recorded turnover of the assessee company as unexplained cash credits, which, thus, had led to double taxation in its hands. Apart from that, the Ld. AR took us through the documentary evidence that was filed by the assessee company in the course

Abhay Chordia, Jaipur vs. The ACIT, Jaipur

In the result the appeal filed by the assessee is allowed

ITA 1121/JPR/2025[2017-18]Status: DisposedITAT Jaipur12 Nov 2025AY 2017-18

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Dheeraj Borad, C.AFor Respondent: Shri Rajesh Ojha, Ld. CIT a

Section 143(1)Section 143(3)Section 250Section 68

cash in bank account and if nothing incriminating is found contrary than addition under section 68 of such cash sales would tantamount to double taxation. 4.22. That though the assessee furnished all the above mentioned supporting evidence but while passing the assessment order the A.O. ignored all these supporting evidences

M/S. Arun Excello Realty Pvt. Ltd., Chennai vs. DCIT, Corporate Circle-1(1), Chennai

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

ITA 2267/CHNY/2025[2022-23]Status: DisposedITAT Chennai12 Nov 2025AY 2022-23

Bench: Shri S.S. Viswanethra Ravi & Shri Amitabh Shuklaआयकर अपील सं./I.T.A. No.2267/Chny/2025 िनधा"रण वष"/Assessment Year: 2022-23 M/S. Arun Excello Realty Private Vs. The Deputy Commissioner Of Limited, 18, Bhattad Towers West Cott Income Tax, Road, Royapettah, Chennai 600 014. Corporate Circle 1(1), Chennai. [Pan: Aafca8363E] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri Shrenik Chordia, C.A. ""थ" की ओर से/Respondent By : Shri R.V. Aroon Prasad, Addl. Cit सुनवाई की तारीख/ Date Of Hearing : 10.11.2025 घोषणा की तारीख /Date Of Pronouncement : 12.11.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 29.07.2025 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For The Assessment Year 2022-23. 2. The Assessee Raised 4 Grounds Of Appeal Amongst Which, The Only Issue Emanates For Our Consideration As To Whether The Ld. Cit(A) Is Justified In Confirming The Addition Made By The Assessing Officer Under Section 41(1) Of The Income Tax Act, 1961 [“Act” In Short].

For Appellant: Shri Shrenik Chordia, C.AFor Respondent: Shri R.V. Aroon Prasad, Addl. CIT

Section 133(6)Section 41(1)

justified. He argued that if the order of the ld. CIT(A) is confirmed, the assessee would suffer double taxation of the same amount in the year under consideration as well as in FY 2023-24. He prayed to delete the addition made by the Assessing Officer ... consequently written off in the books of the assessee, the addition made in the year under consideration is not justified, which amounts to double taxation of the same amount. Thus, the addition made by the Assessing Officer and confirmed by the ld. CIT(A) is liable to be deleted

Indra Reddy Nomula, Hyderabad vs. DCIT., Central Circle-3(3), Hyderabad

In the result, both the appeals of the Assessee are allowed for statistical purposes

ITA 1421/HYD/2025[2020-21]Status: HeardITAT Hyderabad11 Nov 2025AY 2020-21

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita Nos.1421 & 1399/Hyd/2025 (िनधा"रण वष"/Assessment Years 2020-2021 & 2021-2022) Indra Reddy Nomula The Dcit, Vs. Hyderabad. Central Circle-3(3), Pan Ablpn5323M Hyderabad. (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca C. Maheshwar Reddy राज" व "ारा /Revenue By: Sri R Kumaran, Sr. Ar

For Appellant: CA C. Maheshwar ReddyFor Respondent: Sri R Kumaran, Sr. AR

Section 147Section 250

rental income belongs to Indra Reddy Nomula (HUF) and was already offered to tas, and as such the addition made would amount to double taxation, which is bad in law 3. The ld. AO has failed to consider the submissions of the Appellant and erred in making the addition without ... Therefore, the additions made by the Assessing Officer and confirmed by the learned CIT(A) are bad in law and also amounts to double taxation because the HUF has already offered the said income to tax. The learned Authorised Representative of the Assessee has submitted that the learned

Nomula Indra Reddy, Hyderabad vs. DCIT., Central Circle-3(3), Hyderabad

In the result, both the appeals of the Assessee are allowed for statistical purposes

ITA 1399/HYD/2025[2021-22]Status: HeardITAT Hyderabad11 Nov 2025AY 2021-22

For Appellant: CA C. Maheshwar ReddyFor Respondent: Sri R Kumaran, Sr. AR

Section 147Section 250

Dipika Singh, Kolkata vs. ITO, Ward 50(2), Now Ward 50(1), Kolkata

In the result, the appeal of the assessee is allowed

ITA 194/KOL/2025[2017-18]Status: DisposedITAT Kolkata11 Nov 2025AY 2017-18

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm Ito, Ward 50(2) Dipika Singh Now Word 50(1), Bhatendra East Raypara Uttarpan, Manicktala Civic Rajarhat, Barasat, Vs. Centre, Kolkata-700067, Kolkata-700135, West Bengal West Bengal (Appellant) (Respondent) Pan No. Bllps4355P Assessee By : S/ Shri Soumitra Choudhury & Anirban Gupta, Ars Revenue By : Ms. Ruchika Sharma, Dr Date Of Hearing: 04.11.2025 Date Of Pronouncement: 11.11.2025

For Appellant: S/ Shri Soumitra Choudhury &For Respondent: Ms. Ruchika Sharma, DR

Section 145(3)Section 69A

Dipika Singh; A.Y. 2017-18 sales proceeds for which cash was received are added u/s 69A of the Act which would amount to double taxation once as sale and another against as unexplained cash credit which is violate principles of taxation. The ld. AR further contended that Hon’ble ITAT ... provision of section 69A were wrongly invoked by wrong interpretation of the provisions of the Act and ii) that the addition would result in double taxation of the same sales which is not permissible under the Act as has been discussed hereinabove. Accordingly, we set aside the order

Sap India Private Limited, Bangalore vs. Deputy Commissioner of Income-Tax, Circle 6(1)(1), Bangalore

In the result appeal filed by the assessee is partly allowed

ITA 704/BANG/2023[2019-20]Status: DisposedITAT Bangalore11 Nov 2025AY 2019-20

Bench: Shri Prashant Maharishi & Shri Soundararajan K, Jm

Section 115Section 143Section 144BSection 144CSection 234DSection 37Section 92C

Section 115- O of the act should have been charged at the rate of 10% in terms of article 10 of the India German Double Taxation Avoidance Agreement. Thus, assessee claims that the excess tax deducted/withheld/collected under Section 115- O should be refunded. As per ground No. 6 the assessee ... assessee is that dividend distribution tax was calculated originally at the rate of 20.56% paid to its foreign shareholders wherein according to the double taxation avoidance agreement the impugned tax rate should have been 10%. Therefore, the assessee has computed tax under Section 1150 of the act at the rate

Income Tax Officer 17(1)(1), Mumbai vs. Ashok Amritlal Nayak, Mumbai

In the result, appeal of the revenue is dismissed and the C

ITA 3484/MUM/2025[2018-19]Status: DisposedITAT Mumbai11 Nov 2025AY 2018-19

Bench: Shri Anikesh Banerjee, Jm & Ms Padmavathy S, Am

For Appellant: Shri Surendra Mohan, Sr. DRFor Respondent: Shri Rahul Hakani, AR

Section 115BSection 143(1)Section 148Section 151ASection 250Section 68

appreciate that the said sales were already offered to tax in the profit and loss account, and hence, the addition u/s 68 amounts to double taxation, which is not permissible under law. 6. The learned CIT(A) failed to appreciate that the addition

Linklaters LLP, London vs. Assistant Commissioner of Income Tax (International Taxation), Circle (3)(1)(2), Mumbai

ITA 1222/MUM/2025[2022-23]Status: DisposedITAT Mumbai11 Nov 2025AY 2022-23

Bench: Shri Saktijit Dey & Shri Girish Agrawalassessment Year: 2022-23 Linklaters Llp Assistant Commissioner Of C/O. Deloitte Haskins & Sells Income Tax (International Llp, Tower 3, 27-32 Floor, One Taxation) - 3(1)(2), International Centre, Mumbai Elphinstone Mill Compound, Vs. Senapati Bapat Marg, Elphinstone (West), Mumbai – 400 013. (Pan: Aabcl5182G) (Appellant) (Respondent) Present For: Assessee : Shri Niraj Sheth, Advocate Revenue : Shri Krishna Kumar, Sr. Dr Date Of Hearing : 14.08.2025 Date Of Pronouncement : 11.11.2025

For Appellant: Shri Niraj Sheth, AdvocateFor Respondent: Shri Krishna Kumar, Sr. DR

Section 144C(5)Section 9Section 9(1)Section 9(1)(vii)

contradictory positions in the above order. (a). The learned AO held that the appellant is not entitled to the benefits of the India-UK Double Taxation Avoidance Agreement ('DTAA') and at the same time held that the services were performed through a permanent establishment in India Further, the learned

Dy. Commissioner of Income Tax, Central Circle, Kota vs. Sh. Vinod Kumar Jain, Kota

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

ITA 717/JPR/2025[2018-19]Status: DisposedITAT Jaipur10 Nov 2025AY 2018-19

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI GAGAN GOYAL (Accountant Member)

For Appellant: NoneFor Respondent: Mrs. Anita Rinesh, JCIT-DR fu/kZkfjrh dh vksjls@

Section 115BSection 132(4)Section 68Section 69B

jewellery by holding that the income from physical stock is already considered for taxation, any other addition for the same source leads to double taxation of the same without appreciating the facts that the assesse did not femise details about particulars of items and specification of items which can prove ... returns of income for AYs 2018-19 and 2019-20. Adding the value of gold received for re-making under section 68 results in double taxation, as the same is taxed twice. First as part of the firm’s profit and Second, as unexplained income of the appellant. The appellant

Chidambaram Chettiar Krishnan, Ranipet vs. ACIT, Circle-1, Vellore

In the result, the appeal of the assessee is allowed in terms above

ITA 2202/CHNY/2025[2017-18]Status: DisposedITAT Chennai10 Nov 2025AY 2017-18

Bench: Shri Manu Kumar Giri & Shri Jagadish

Section 115BSection 68

already been offered to tax in the return filed for AY 2017-18, no separate addition can be made. This would amount to double taxation. However, the said amount of Rs. Rs.20,59,556/-, is to be taxed at a higher rate in terms of section 68 r.w.s. 115BBE

Tungsten Automation England Ltd, United Kingdom vs. DCIT, Intl Taxation Circle-3(1)(1), Delhi

In the result, appeal of the assessee is partly allowed

ITA 1957/DEL/2025[2018-19]Status: DisposedITAT Delhi10 Nov 2025AY 2018-19

Bench: Shri Vikas Awasthy & Shri Brajesh Kumar Singh[Assessment Year: 2018-19]

Section 147Section 9(1)Section 9(1)(vii)

XXXX 10. That the Respondent/ DRP erred in law in concluding satisfaction of the make available condition under Article 13(4)(c) of the Double Taxation Avoidance Agreement between India and United Kingdom ("India - UK DTAA"), without specifically stating how provision of e-invoicing software and other related services

DCIT, I.T.O. Delhi vs. Rathi Steel and Power Limited, Delhi

In the result the appeal of the Revenue stands dismissed

ITA 2720/DEL/2024[2017-2018]Status: DisposedITAT Delhi10 Nov 2025AY 2017-2018

Bench: Shri Challa Nagendra Prasad & Shri Avdhesh Kumar Mishraita No.2720/Del/2024, A.Y. 2017-18 Dy. Commissioner Of Vs. Rathi Steel & Power Ltd., Income Tax, Circle-19(1), Chauhan Market, Room No. 221, 2Nd Floor, Madanpur Khadar, C. R. Building, I. P. Estate Near Shopping Complex, New Delhi Sarita Vihar, New Delhi-76 Pan: Aaacr1435K (Appellant) (Respondent) Appellant By Sh. Mayank Patawari, Advocate Respondent By Sh. Ajay Kumar Arora, Sr. Dr Date Of Hearing 13/08/2025 Date Of Pronouncement 10/11/2025 Order Per Avdhesh Kumar Mishra, Am The Appeal Of The Revenue For Assessment Year (‘Ay’) 2017-18 Is Directed Against The Order Dated 27.03.2024 Of The Commissioner Of Income Tax (Appeals)-26, New Delhi [‘Cit(A)’].

Section 68

deposit of cash in bank accounts and if nothing incriminating is found contrary then addition u/s 68 of such cash sale would tantamount to double taxation. In several recent judgements such as in the cases of DCIT vs M/s. Bhanu Infrabuild Pvt. Ltd. 2023 TAXSCAN (ITAT-Del) 2159; DCIT ... sales once as a regular sale shown in Profit & Loss Account and again the same under section 68 of the Act, which tantamount to double taxation being contrary to the law and accounting principles. He submitted that the Ld. AO had once treated cash sales shown in the Profit & Loss

DCIT Circle 4(2), New Delhi vs. Canon India Pvt. Ltd., New Delhi

In the result, to sum up and conclude:

ITA 1038/DEL/2023[2005-06]Status: DisposedITAT Delhi10 Nov 2025AY 2005-06

Bench: Shri Challa Nagendra Prasad & Shri Naveen Chandra

For Appellant: Shri Himanshu Sinha, AdvFor Respondent: Shri Vijay B. Basanta, CIT-DR

Section 10ASection 143(3)Section 254Section 92C

assessee claimed Foreign Tax Credit (FTC) under Section 90 of the Income- tax Act, 1961, read with Article 23 of the India-Japan Double Taxation Avoidance Agreement (DTAA). The Assessing Officer, while completing the assessment, disallowed the FTC claim on the ground that in the same year, the income corresponding ... supra) decision entirely rests on the interpretation of the expression "subject to tax" which has been used in Article 24 pertaining to Elimination of Double Taxation in the India-UK DTAA. The Assessee's case arises in the context of Article 23 of the India- Japan DTAA which does

Canon India Pvt. Ltd, Gurugram vs. Neac, Delhi

In the result, to sum up and conclude:

ITA 585/DEL/2021[2003-04]Status: DisposedITAT Delhi10 Nov 2025AY 2003-04

Bench: Shri Challa Nagendra Prasad & Shri Naveen Chandra

For Appellant: Shri Himanshu Sinha, AdvFor Respondent: Shri Vijay B. Basanta, CIT-DR

Section 10ASection 143(3)Section 254Section 92C

Sunil Kumar Mehta, Dariapur vs. I.T.O. Ward 2(2)(1), Surat

In the result, the appeal of the assessee is partly allowed in the manner indicated above

ITA 265/SRT/2025[2016-17]Status: DisposedITAT Surat07 Nov 2025AY 2016-17

Bench: Shri Sanjay Garg & Shri Bijayananda Prusethआयकरअपीलसं./Ita No.265/Srt/2025 Assessment Year: 2016-17 (Hybrid Hearing) Shri Sunik Kumar Mehta बनाम/ Ito, A – 24, Asthvinayak Complex, Vs. Ward- 2(2)(1), Dariapur, Ahmedabad - 380004 Surat "थायीलेखासं./जीआइआरसं./Pan/Gir No: Allpm1108P (Appellant) (Respondent) Appellant By Shri Chirag Shah, Ca Respondent By Shri Ajay Uke, Sr. Dr Date Of Hearing 11/08/2025 Date Of Pronouncement 07/11/2025

Section 147Section 148Section 234ASection 250

filed by the assessee for the relevant AY 2016-17. Therefore, addition in this regard should not be made since it would amount to double taxation. It was further submitted that the transactions amounting to Rs.89,53,637/- were not accommodation entries as the transactions were entered at arm length

Deputy Commissioner of Income Tax, TDS Circle, Coimbatore vs. Coimbatore Municipal Corporation, Coimbatore

In the result, the appeal of the Revenue is dismissed

ITA 1690/CHNY/2025[2017-18]Status: DisposedITAT Chennai07 Nov 2025AY 2017-18

Bench: Shri Ss Viswanethra Ravi & Shri Amitabh Shuklaआयकर अपील सं./Ita No.1690/Chny/2025 Assessment Years: 2017-18 Deputy Commissioner Of Income Coimbatore Municipal Corporation, Tax, No.1, Corporation Building, Tds Circle, Big Bazaar Street, Coimbatore, Coimbatore. Tamil Nadu-641 001. [Pan: Aaalc1419P]

For Appellant: Mr.B.Ramakrishnan, F.C.AFor Respondent: Ms.Gouthami Manivasagam, JCIT

Section 268A

otherwise is under question, or ii. Appeals of International taxation charges where the dispute relates to the applicability of the provisions of a Double Taxation Avoidance Agreement or otherwise. m.Any other case or class of cases where in the opinion of the Board it is necessary to contest