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“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
97
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

DCIT, Circle- 1(1)(1), International Taxation, New Delhi vs. Convergys Customer Management Group Inc., New Delhi

In the result, the assessee’s both appeals are allowed as above

ITA 130/DEL/2018[2013-14]Status: DisposedITAT Delhi30 Sept 2025AY 2013-14

Bench: Shri Vikas Awasthy & Shri Avdhesh Kumar Mishraita No.7727/Del/2017, A.Y. 2013-14 Ita No.7924/Del/2018, A.Y. 2014-15 Ita No.1086/Del/2022, A.Y. 2017-18 Ita No.667/Del/2023, A.Y. 2018-19 Ita No.668/Del/2023, A.Y. 2019-20 Ita No.3512/Del/2023, A.Y. 2021-22 Ita No.1892/Del/2025, A.Y. 2022-23 Concentrix Cvg Customer Deputy Commissioner Management Group Inc., (Earlier Of Income Tax, Known As ‘Convergys Customer Vs Circle - 1(2)(1), Management Group Inc.’) International Taxation, C/O Pwc Pvt. Ltd., E-2 Tower, Civic Centre Sucheta Bhawan, Minto Road Gate No. 2, 1St Floor, New Delhi 11-A, Vishnu Digambar Marg, New Delhi Pan: Aaccc8989M (Appellant) (Respondent)

Section 234ASection 270A

countries had desisted from making any determination on whether Convergence US had established an Indian PE as per Article 5 of the India-US Double Taxation Avoidance Agreements. However, and solely with the objective of settling that dispute which straddled multiple years, the parties appear to have agreed ... company incorporated in the United States of America (‘USA’), is a tax resident of USA under terms of Article-4 of the Double Taxation Avoidance Agreement (‘DTAA’) between India and USA. The assessee provides outsourced customer and marketing support services as well as comprehensive customer management services. Convergys Indian Services

Convergys Customer Management Group Inc., New Delhi vs. DCIT, Circle- 1(2)(1), International Taxation, New Delhi

In the result, the assessee’s both appeals are allowed as above

ITA 7727/DEL/2017[2013-14]Status: DisposedITAT Delhi30 Sept 2025AY 2013-14

Bench: Shri Vikas Awasthy & Shri Avdhesh Kumar Mishraita No.7727/Del/2017, A.Y. 2013-14 Ita No.7924/Del/2018, A.Y. 2014-15 Ita No.1086/Del/2022, A.Y. 2017-18 Ita No.667/Del/2023, A.Y. 2018-19 Ita No.668/Del/2023, A.Y. 2019-20 Ita No.3512/Del/2023, A.Y. 2021-22 Ita No.1892/Del/2025, A.Y. 2022-23 Concentrix Cvg Customer Deputy Commissioner Management Group Inc., (Earlier Of Income Tax, Known As ‘Convergys Customer Vs Circle - 1(2)(1), Management Group Inc.’) International Taxation, C/O Pwc Pvt. Ltd., E-2 Tower, Civic Centre Sucheta Bhawan, Minto Road Gate No. 2, 1St Floor, New Delhi 11-A, Vishnu Digambar Marg, New Delhi Pan: Aaccc8989M (Appellant) (Respondent)

Section 234ASection 270A

countries had desisted from making any determination on whether Convergence US had established an Indian PE as per Article 5 of the India-US Double Taxation Avoidance Agreements. However, and solely with the objective of settling that dispute which straddled multiple years, the parties appear to have agreed ... company incorporated in the United States of America (‘USA’), is a tax resident of USA under terms of Article-4 of the Double Taxation Avoidance Agreement (‘DTAA’) between India and USA. The assessee provides outsourced customer and marketing support services as well as comprehensive customer management services. Convergys Indian Services

Asst. Commissioner of Income Tax, Central Circle, Muzaffarpur vs. Ajit Kumar, Bettiah

In the result, the appeal filed by the Revenue is dismissed

ITA 239/PAT/2024[2017]Status: DisposedITAT Patna29 Sept 2025

Bench: Shri George Mathan & Shri Rakesh Mishra

Section 115BSection 143(3)Section 148Section 250Section 40A(3)Section 69

profit rate on that for determining the profit, takes care of all disallowances and again disallowing these expenditures u/s 40A(3), would lead to double taxation of the same amount, because those amounts have already been considered in the net profit. (d) In this respect, the following judicial pronouncements which ... estimating a net profit @5.39% of the estimated out of books turnover shall not go hands in hand as it will lead to double taxation of the same income. Once the net income rate is applied, obviously the income determined takes care of all the provisions

ACIT(It)1.2.2 Mumbai, Bkc Mumbai vs. Bcd Travel Services Bv, Netherlands

In the result, appeal filed by the Revenue is dismissed

ITA 4240/MUM/2025[2018]Status: DisposedITAT Mumbai29 Sept 2025

Bench: Shri Saktijit Dey, Hon'Ble & Shri Girish Agrawal

For Appellant: Ms. Hirali Desai, Shri Hardik Nirmal and Ms. Tejal Saraf, CAsFor Respondent: Shri Krishna Kumar, Sr. DR
Section 143(3)Section 9(1)(vi)

clause (2) read with clause 3(a) of Article 12 of the India-Netherlands Double Taxation Avoidance Agreement (DTAA), received by the assessee for services rendered under the Global Framework Network Agreement (GNFA). Since the issues are identical except for variation in the quantum of addition made for which ... earned by the assessee in the form of support fees is neither royalty nor FTS under the provision of Article 12 of India-Netherlands Double Taxation Avoidance Agreement." (Emphasis supplied)” 4.4. In the observations of the ld. Assessing Officer, for the information communicated, the same is special commercial knowledge, experience

ACIT (It) 1.2.2 Mumbai, Bkc vs. Bcd Travel Services Bv, Netherlands

In the result, appeal filed by the Revenue is dismissed

ITA 4219/MUM/2025[2017-18]Status: DisposedITAT Mumbai29 Sept 2025AY 2017-18

Bench: Shri Saktijit Dey, Hon'Ble & Shri Girish Agrawal

For Appellant: Ms. Hirali Desai, Shri Hardik Nirmal and Ms. Tejal Saraf, CAsFor Respondent: Shri Krishna Kumar, Sr. DR
Section 143(3)Section 9(1)(vi)

clause (2) read with clause 3(a) of Article 12 of the India-Netherlands Double Taxation Avoidance Agreement (DTAA), received by the assessee for services rendered under the Global Framework Network Agreement (GNFA). Since the issues are identical except for variation in the quantum of addition made for which ... earned by the assessee in the form of support fees is neither royalty nor FTS under the provision of Article 12 of India-Netherlands Double Taxation Avoidance Agreement." (Emphasis supplied)” 4.4. In the observations of the ld. Assessing Officer, for the information communicated, the same is special commercial knowledge, experience

Satellite Developers Private Limited, Mumbai vs. Assistant Commissioner of Income Tax Central Circle 5(4), Mumbai

In the result, the grounds appeal raised by the assessee are allowed

ITA 4131/MUM/2025[2018-19]Status: DisposedITAT Mumbai29 Sept 2025AY 2018-19

Bench: Shri Pawan Singh& Smt.Renu Jauhri(Physical Hearing)

Section 143(1)Section 254(1)

Shah again in the Total Income of the year under consideration i.e. A.Y. 2018-19 amounting to Rs.1,01,12,235/- would tantamount to double taxation and proceeded by confirming the said addition without giving specific directions to the learned A.O. to exclude the said income from assessment of Income

Avana Global Fzco, Mumbai vs. Deputy Commissioner of Income Tax (International Tax)-1(1)(2), Mumbai

In the result, appeal of the assessee is allowed

ITA 1788/MUM/2025[2022-23]Status: DisposedITAT Mumbai29 Sept 2025AY 2022-23

Bench: Shri Saktijit Dey, Hon'Ble & Shri Girish Agrawalassessment Year: 2022-2023 Avana Global Fzco Deputy Commissioner Of Unit No.2002-2004, 2201- Income-Tax (International Tax) 2204 & 2103, 20Th, 21St & – 1(1)(2), Mumbai 22Nd Floor, Building Q 2, Aurum Q Parc Gen 4/1, Vs. Tic, Ghansoli, Thane Belapur Road, Navi Mumbai – 400701. (Pan: Aadcb4021A) (Appellant) (Respondent) Present For: Assessee : Shri Dhanesh Bafna A/W. Shri Hardik Nirmal & Ms. Hinal Shah, Ca Revenue : Shri Satya Pal Kumar, Cit Dr Date Of Hearing : 21.08.2025 Date Of Pronouncement : 29.09.2025 O R D E R

For Appellant: Shri Dhanesh Bafna a/w. Shri Hardik Nirmal and Ms. Hinal Shah, CAFor Respondent: Shri Satya Pal Kumar, CIT DR
Section 143(3)Section 144Section 144C(5)Section 153Section 44B

Mumbai [DCTT(IT)] and Hon'ble Dispute Resolution Panel-1 (DRP) erred in denying the benefit of Article 8 of the Double Taxation Avoidance Agreement between India and UAE (Tax Treaty) on the shipping income [including inland haulage charges (IHC)] derived from operation of ships in international traffic ... However, ground No. 4, 5 and 6, all relate to one issue in respect of denying the benefit of Article 8 under India-UAE Double Taxation Avoidance Agreement (DTAA) and holding it liable to be taxed in India u/s.44B in respect of shipping income

Maersk Logistics & Services International A/S (Erstwhile, Damco International A/S), Mumbai vs. Dy. Commissioner of Income Tax, International Tax (It) Circle 3(2)(1), Mumbai

In the result, both the appeals of the assessee are partly allowed

ITA 1329/MUM/2025[2022-23]Status: DisposedITAT Mumbai29 Sept 2025AY 2022-23

Bench: SHRI SAKTIJIT DEY, HON’BLE (Vice President), SHRI GIRISH AGRAWAL (Accountant Member)

For Appellant: Shri Manish Kanth, ARFor Respondent: Shri Satya Pal Kumar, CIT DR
Section 115A(1)(b)Section 144CSection 144C(5)Section 153Section 234BSection 234CSection 270ASection 9(1)(vii)

during the year by the assessee, treated as fees for technical services and royalty under the Act as well as under the India-Netherlands Double Taxation Avoidance Agreement (DTAA). 2 Maersk Logistics and Services International A/S. AY 2022-23 4. Brief facts of the case are that assessee filed

Shri Krishna Enterprise, Nadiad vs. The ITO, Ward-1, Nadiad

In the result, the appeal is allowed for statistical purposes

ITA 1419/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad26 Sept 2025AY 2017-18

Bench: Shri Siddhartha Nautiyal & Shri Makarand V.Mahadeokarasstt.Year : 2017-18 Shri Krishna Enterprise Vs. The Ito, Ward-1 (Partnership Firm) Nadiad. Gf, Snri Krishna Palace Dabhan Chokdi, Dabhan Nadiad, Gujarat. Pan : Acwfs 6389 J (Applicant) (Responent) : Shri B.T. Thakkar, Ar Assessee By Revenue By : Shri Amit Pratap Singh, Sr.Dr सुनवाई क" तारीख/Date Of Hearing : 25/09/2025 घोषणा क" तारीख /Date Of Pronouncement: 26/09/2025 आदेश आदेश/O R D E R आदेश आदेश

For Respondent: Shri Amit Pratap Singh, Sr.DR
Section 144

part. The affidavit also stresses that the matter involves substantial merits, namely validity of assessment framed on a non-existent entity and double taxation of income already accounted for in the hands of the proprietor. 3 3. We have given our thoughtful consideration to the reasons advanced by the assessee ... were placed in the paper book. It was argued that taxing the same income again in the name of the dissolved firm amounts to double taxation and the addition deserves to be deleted. 6. The learned Departmental Representative (DR), on the other hand, supported the orders of the authorities below

Dattaprasad Radhakisan Revgade, Hivargaon vs. ITO Ward 2, Ahmednagar

In the result, appeal of the assessee is allowed for statistical purpose

ITA 1897/PUN/2025[2018-19]Status: DisposedITAT Pune26 Sept 2025AY 2018-19

Bench: Ms.Astha Chandra, Judicialmember & Dr.Dipak P. Ripoteआयकर अपऩल सं. / Ita No.1897/Pun/2025 निर्धारण वषा / Assessment Year: 2018-19 Dattaprasad Radhakisan V The Income Tax Officer, Revgade, S Ward-2, Ahmednagar. At Hivargaon Post Dongargaon, Tal Aklole, Ahmednagar – 422609. Pan: Cddpr8213C Appellant/ Assessee Respondent / Revenue Assessee By Shri Piyush Bafna – Ar Revenue By Shri Ambarnath Khule – Jcit(Dr) Date Of Hearing 03/09/2025 Date Of Pronouncement 26/09/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Filed By The Assessee Against The Order Of Ld.Commissioner Of Income Tax Appeal(Nfac) Passed Under Section 250 Of The Income Tax Act, 1961 For A.Y.2018-19 Dated 23.06.2025 Emanating From The Assessment Order Under Section 147 R.W.S 144 Read With Section 144B Of The Income Tax Act, 1961

Section 144Section 144BSection 147Section 148Section 148ASection 149(1)(b)Section 151Section 250Section 250(6)

addition of Rs 2,73,180/-on account of Business Income which is incorrect both on facts and in law and which amounts to double taxation and hence, the said addition deserves to be quashed. 12. On the facts and in the circumstances of the case

Dy. Commissioner of Income Tax, Central Circle-1, Auranagabad., Aurangabad vs. Navin Hanumanprasad Bagadiya, Aurangabad

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

ITA 990/PUN/2024[2014-15]Status: DisposedITAT Pune26 Sept 2025AY 2014-15

Bench: Dr.Manish Borad & Ms. Astha Chandra

For Appellant: Shri Amol KhairnarFor Respondent: Shri Abhay N. Agrawal
Section 132Section 143(2)Section 143(3)Section 153CSection 250Section 69Section 69A

erred in law and facts by holding that addition made on account of unexplained investments u/s 69 amount to double taxation. 7. Whether on the facts and in the circumstances of the case and in law, the Ld. CIT(A) has erred in law and in facts by not appreciating ... that since the impugned transactions have already been owned by DNK, therefore, taxing the same amount in the hands of assessee would amount to Double taxation. Ld.CIT(W) gave reference to the Affidavit given by DNK before ld. ACIT, 5 Navin Hanumanprasad Bagadiya Circle-1, Aurangabad on 29.09.2021 and before

Linga Naveenkumar, Hyderabad vs. ITO., Ward-4(1), Hyderabad

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

ITA 551/HYD/2025[2017-18]Status: DisposedITAT Hyderabad26 Sept 2025AY 2017-18

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha, G.आ.अपी.सं /Ita No.551/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2017-18) Shri Linga Naveenkumar Vs. Income Tax Officer Hyderabad Ward 4(1) Pan:Aafpn0021P Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Advocate K Prabhabati राज" व "ारा/Revenue By:: Shri Tv Vamshidhar, Sr.Ar सुनवाई की तारीख/Date Of Hearing: 24/09/2025 घोषणा की तारीख/Pronouncement: 26/09/2025 आदेश/Order

For Appellant: Advocate K PrabhabatiFor Respondent: : Shri TV Vamshidhar, Sr.AR
Section 148

assessee is assessed by considering the salary income as well as other income of the assessee. Therefore, there is no question of double taxation of the same income. Page 8 of 10 ITA No 551 of 2025 Linga Naveenkumar 10. We have considered the rival submission as well as relevant

DCIT., Central Circle-3(2), Hyderabad vs. Satyam Venture Engineering Service Pvt Ltd, Hyderabad

In the result, appeal filed by the Revenue is dismissed

ITA 1242/HYD/2025[2022-23]Status: DisposedITAT Hyderabad26 Sept 2025AY 2022-23

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha, G.आ.अपी.सं /Ita No.1242/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2022-23) Dy. Cit Vs. Satyam Venture Central Circle 3(2) Engineering Service Hyderabad Private Limited Hyderabad Pan: Aafcs3287D (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Ca Ev Sri Krishna राज" व "ारा/Revenue By:: Shri T.V. Vamsidhar, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 24/09/2025 घोषणा की तारीख/Pronouncement: 26/09/2025 आदेश/Order Per Vijay Pal Raothis Appeal By The Revenue Is Directed Against The Order Dated 14/06/2025 Of The Learned Cit (A), Hyderabad -11 For The A.Y.2022-23. 2. The Revenue Has Raised The Following Grounds Of Appeal:

For Appellant: CA EV Sri KrishnaFor Respondent: : Shri T.V. Vamsidhar, Sr. AR
Section 40

learned DRP recorded that such payments amounted to Fee for Technical Services (FTS), and in the absence of FTS clause in the India - Thailand Double Taxation Avoidance Agreement (DTAA), the same have to be taxed as other income under Article 22 of DTAA, and for non-deduction

ACIT, Corporate Circle 1(1), Chennai vs. Durr India Private Limited, Chennai

In the result, the appeal filed by the Revenue is partly-allowed

ITA 1638/CHNY/2025[2019-20]Status: DisposedITAT Chennai26 Sept 2025AY 2019-20

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 1638/Chny/2025 िनधा"रण वष"/Assessment Year: 2019-20 The Acit, Durr India Pvt. Ltd., Corporate Circle 1 (1), Vs. 471, Prestige Polygon, Chennai. Anna Salai, Nandanam, Chennai – 600 035. Pan: Aaacd 3568P (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Ms. Gouthami Manivasagam, Jcit ""यथ" क" ओर से/Respondent By : Shri Suhrith Parthasarathy, Advocate सुनवाई क" तारीख/Date Of Hearing : 25.09.2025 घोषणा क" तारीख/Date Of Pronouncement : 26.09.2025

For Appellant: Ms. Gouthami Manivasagam, JCITFor Respondent: Shri Suhrith Parthasarathy
Section 115Section 143(1)Section 250Section 40

Directing refund of excess Dividend Distribution Tax (DDT) paid beyond the 10% rate under the India-Germany Double Taxation Avoidance Agreement (DTAA), relying on tribunal decisions. 6. Aggrieved by the order of the FAA, Revenue has filed the present appeal before the Tribunal. Two issues arise for our adjudication ... Distribution Tax (DDT) 12. The FAA had directed refund of excess Dividend Distribution Tax (DDT) paid beyond 10% of rate under the India-Germany Double Taxation Avoidance Agreement (DTAA) by observing as under:- 7.5 Ground no. 7 to 9 pertains to Excess DDT Paid. Under the provisions of the India

Deputy Commissioner of Income Tax, Chennai vs. Mohanlal Jewellers Private Limited, Chennai

ITA 1393/CHNY/2025[2017-18]Status: DisposedITAT Chennai26 Sept 2025AY 2017-18

Bench: Shri Aby T. Varkey & Shri S.R.Raghunathaआयकर अपील सं./Ita Nos.1178 To 1182/Chny/2025 िनधारण वष/Assessment Years: 2017-18 To 2021-22 M/S. Mohanlal Jewellers Pvt. Ltd, Old No.68-69, Nsc Bose Road, Sowcarpet, Chennai-600 001. V. The Dcit, Central Circle-3(3), Chennai. [Pan: Aafcm 9906 M] (अपीलाथ/Appellant) (यथ/Respondent) आयकर अपील सं./Ita Nos.1393 To 1397/Chny/2025 िनधारण वष/Assessment Years: 2017-18 To 2021-22 The Dcit, Central Circle-3(3), Chennai. V. M/S. Mohanlal – Jewellers Pvt. Ltd., Old No.68-69, Nsc Bose Road, Sowcarpet, Chennai-600 001. [Pan: Aafcm 9906 M] (अपीलाथ/Appellant) (यथ/Respondent) Assessee By : Mr. D. Anand, Advocate Department By : Ms. E. Pavuna Sundari, Cit सुनवाई क तारीख/Date Of Hearing : 05.08.2025 घोषणा क तारीख /Date Of Pronouncement : 26.09.2025

For Appellant: Mr. D. Anand, AdvocateFor Respondent: Ms. E. Pavuna Sundari, CIT
Section 132Section 143(3)Section 153A

Revenue for sustaining the addition(s) being impugned before us has no legs to stand on, as it would amount to double taxation of the same amount, which is impermissible in law. ITA Nos.1178 to 1182/Chny/2025 & ITA Nos.1393 to 1397/Chny/2025 & (AYs: 2017-18 to 2021-22) M/s. Mohanlal Jewellers ... Revenue for sustaining the addition(s) being impugned before us has no legs to stand on, as it would amount to double taxation of the same amount, which is impermissible in law. ITA Nos.1178 to 1182/Chny/2025 & ITA Nos.1393 to 1397/Chny/2025 & (AYs: 2017-18 to 2021-22) M/s. Mohanlal Jewellers

Redington Distribution Pte Ltd., Singapore vs. ACIT, Intl Taxn Circle-2(1), Chennai

In the result, all the appeals of the assessee are allowed

ITA 1217/CHNY/2025[2020-21]Status: DisposedITAT Chennai26 Sept 2025AY 2020-21

Bench: Shri Aby T. Varkey & Shri S.R.Raghunatha

For Appellant: Mr.Ashik Shah, CAFor Respondent: Ms.Anitha, Addl.CIT
Section 133ASection 139Section 148Section 270A(2)Section 271(1)(c)

income in Singapore to ensure ITA Nos.1215 to 1217/Chny/2025 (AYs 2017-18, 2018-19 & 2020-21) M/s. Redington Distribution Pte. Ltd. :: 13 :: avoidance of double taxation in Singapore on the income being brought to tax in India. We thus observe that, the alternate remedy was availed by the assessee only

Redington Distributions Pte Ltd., Singapore vs. ACIT, Intl Taxn Circle-2(1), Chennai

In the result, all the appeals of the assessee are allowed

ITA 1216/CHNY/2025[2018-19]Status: DisposedITAT Chennai26 Sept 2025AY 2018-19

Bench: Shri Aby T. Varkey & Shri S.R.Raghunatha

For Appellant: Mr.Ashik Shah, CAFor Respondent: Ms.Anitha, Addl.CIT
Section 133ASection 139Section 148Section 270A(2)Section 271(1)(c)

income in Singapore to ensure ITA Nos.1215 to 1217/Chny/2025 (AYs 2017-18, 2018-19 & 2020-21) M/s. Redington Distribution Pte. Ltd. :: 13 :: avoidance of double taxation in Singapore on the income being brought to tax in India. We thus observe that, the alternate remedy was availed by the assessee only

M/S. Redington Distribution Pte Ltd., Singapore vs. ACIT, Intl Taxn Circle-2(1), Chennai

In the result, all the appeals of the assessee are allowed

ITA 1215/CHNY/2025[2017-18]Status: DisposedITAT Chennai26 Sept 2025AY 2017-18

Bench: Shri Aby T. Varkey & Shri S.R.Raghunatha

For Appellant: Mr.Ashik Shah, CAFor Respondent: Ms.Anitha, Addl.CIT
Section 133ASection 139Section 148Section 270A(2)Section 271(1)(c)

income in Singapore to ensure ITA Nos.1215 to 1217/Chny/2025 (AYs 2017-18, 2018-19 & 2020-21) M/s. Redington Distribution Pte. Ltd. :: 13 :: avoidance of double taxation in Singapore on the income being brought to tax in India. We thus observe that, the alternate remedy was availed by the assessee only

DCIT, Pune vs. Barclays Global Service Centre Pvt Ltd, Chennai

In the result, the appeal filed by the Revenue is dismissed

ITA 2353/PUN/2024[2009-10]Status: DisposedITAT Chennai26 Sept 2025AY 2009-10

Bench: Shri Aby T. Varkey & Shri Jagadishआयकर अपील सं./ Ita No.2353/Pun/2024 िनधा8रण वष8 /Assessment Year: 2009-10

For Appellant: Shri Percy Pardiwala, Sr. counselFor Respondent: Ms. E. Pavuna Sundari, CIT
Section 143(3)Section 195(2)Section 40

r.w.s 90(2) of the Act, the taxability for a non-resident taxpayer is determined based on provision of the Act or the relevant Double Taxation Avoidance Agreement (DTAA), whichever is more beneficial to the taxpayer and as the BB PLC qualifies as a tax resident of UK within

ACIT, Central Circle-2(4), Bangalore vs. Ramchandra Naveen, Bangalore

ITA 2083/BANG/2024[2018-19]Status: DisposedITAT Bangalore26 Sept 2025AY 2018-19

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubey

For Appellant: Shri. V. Srinivasan, AdvocateFor Respondent: Shri. Subramanian S, JCIT(DR)(ITAT), Bangalore
Section 132(4)Section 153A

INCOME TAX APPELLATE TRIBUNAL "B" BENCH : BANGALORE BEFORE SHRI. LAXMI PRASAD SAHU, ACCOUNTANT MEMBER AND SHRI. KESHAV DUBEY, JUDICIAL MEMBER