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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

Uniseven Engineering and Infrastructure Pvt. Ltd., Kolkata vs. DCIT, Circle - 7(1), Kolkata

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

ITA 2651/KOL/2024[2014-15]Status: DisposedITAT Kolkata22 Apr 2025AY 2014-15

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm]

Section 143(3)Section 147Section 148Section 148ASection 68

offered to tax whatever amount on the said sales and if at all these sales are again added the same will be double taxation which is not permissible under the Act. The case of the assessee finds support from the decision of ITO Vs. Ashapurna Petrochem Marketing

Kumar Ranganathan, Bangalore vs. DCIT Circle 1(1)(1), Bangalore

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

ITA 20/BANG/2025[2021-22]Status: DisposedITAT Bangalore22 Apr 2025AY 2021-22

Bench: Shri Laxmi Prasad Sahu & Shri Keshav Dubeyassessment Year: 2021-22

For Appellant: Sri Harish Sampangi, A.RFor Respondent: Ms. Neha Sahay, D.R
Section 139(1)Section 143(1)Section 154Section 250Section 90

dated 13/10/2022. Despite the assessee’s bonafide payment of foreign taxes and the explicit intent of the India-United States Double Taxation Avoidance Agreement (DTAA) to prevent double taxation, the ld. ADDL/JCIT(A) has, by strictly enforcing a procedural timeline, effectively imposed an additional tax burden contrary to the substantive ... treaty framework governing FTC claims emphasizes substantive justice over procedural technicalities. The principle that treaties and substantive provisions of domestic law intended to mitigate double taxation should not be nullified by procedural lapses is well recognized in judicial precedents. In view of the above the ld. A.R. for the assessee

Shakti Hormann Private Limited, Hyderabad vs. DCIT Circle -3(1), Hyderabad

In the result, appeals filed by the assessee for both the assessment years 2017-18 and 2018-19 are partly allowed

ITA 452/HYD/2022[2018-19]Status: DisposedITAT Hyderabad21 Apr 2025AY 2018-19

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita-Tp No.451/Hyd/2022 & 452/Hyd/2022 (निर्धारण वर्ा/Assessment Year: 2017-18 & 2018-19) Shakti Hormann Private Vs. Asst.Commissioner Of Limited Income Tax Hyderabad Circle-3(1) [Pan : Aadcs4024Q] Hyderabad (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri P.Murali Mohan Rao, Ar रधजस् व द्वधरध/Revenue By: Shri B.Bala Krishna, Cit-Dr सुिवधई की तधरीख/Date Of Hearing: 15/04/2025 घोर्णध की तधरीख/ 21/04/2025 Date Of Pronouncement: आदेश / Order Per Vijay Pal Rao: These Appeals Filed By The Assessee Are Directed Against The Assessment Orders Dated 21.07.2022 & 28.07.2022 Passed U/S 143(3) R.W.S. 144C(13) Of The Income Tax Act, 1961 (“The Act”) In Pursuant To The Directions Of The Dispute Resolution Panel (“The Drp”) U/S 144C(5) Of The Act For The Assessment Year 2017-18 & 2018-19 Respectively. 2. For The Assessment Year 2017-18, The Assessee Has Raised The Following Grounds Of Appeal :

For Appellant: Shri P.Murali Mohan Rao, ARFor Respondent: Shri B.Bala Krishna, CIT-DR
Section 143(3)Section 144C(5)Section 92C

government grant which is already mentioned in the respective schedule in Return of Income filed by the assessee and adding the same leads to double taxation. 6. Erred in upheld the addition of relating to variance of Rs. 80,64,589/- towards total amount of disallowance

ITO Ward-46(1), Kolkata vs. Aloke Kumar Banerjee, Howrah

In the result, appeal of the revenue is dismissed

ITA 861/KOL/2024[2011-12]Status: DisposedITAT Kolkata21 Apr 2025AY 2011-12

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyआयकर अपील सं/Ita No.861/Kol/2024 (नििाारण वर्ा / Assessment Year : 2011-2012) Ito, Ward-46(1), Kolkata Vs Aloke Kumar Banerjee, Unit No.A/08/05, Kolkata West International City, Howrah Amta Road & Bombay Road Crossing Salap More, Howrah-711409 Pan No. :Ailpb 4570 D (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) नििााररती की ओर से /Assessee By : Shri Anuj Musaddi, Ar राजस्व की ओर से /Revenue By : Shri Sailen Samadder, Addl. Cit-Sr. Dr सुनवाई की तारीख / Date Of Hearing : 20/02/2025 घोषणा की तारीख/Date Of Pronouncement : 21/04/2025 आदेश / O R D E R Per Rajesh Kumar, Am : This Is An Appeal Filed By The Revenue Against The Order Dated 15.02.2024 Passed By The Ld. Cit(A), National Faceless Appeal Centre (Nfac), Delhi, For The Assessment Year 2011-2012, On The Following Grounds :- 1. Whether On The Facts & Circumstances Of The Case, The Ld Cit(A) Was Right In Law As Well As On Facts In Deleting The Addition Of Rs. 2,87,12,120/- As Unexplained Cash Deposited In Bank Accounts Without Considering The Facts That The Asseseee Failed To Reconcile The Cash Deposit Of Rs. 2,87,12,210/-. 2. Whether On The Facts & Circumstances Of The Case, The Ld Cit(A) Was Right In Law As Well As On Facts In Deleting The Addition Of Rs. 1,71,925 As Difference In Capital Account As Unexplained Cash Credit Into Books Of Assesee U/S 68 Of The It Act, Without Considering The Facts That The Difference Of Rs. 171925/- Could Not Be Explained By The Assessee.

For Appellant: Shri Anuj Musaddi, ARFor Respondent: Shri Sailen Samadder, Addl. CIT-Sr. DR
Section 68

that the ld. CIT(A) has recorded a clear finding that if the addition made by the AO is sustained ,it would amount to double taxation in the hands of the assessee in respect of the same income. Therefore, we do not see any reason to interfere with the findings

Selvi, Trichy vs. Income Tax Officer, Ward 1(2), Trichy

In the result, the appeal filed by the assessee is allowed

ITA 119/CHNY/2025[2017-18]Status: DisposedITAT Chennai21 Apr 2025AY 2017-18

Bench: Shri Manu Kumar Giri & Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 119/Chny/2025 िनधा"रण वष"/Assessment Year: 2017-18 Ms. Selvi, The Income Tax Officer, 30, North Street, Ward 1(2), Rockfort, Vs. Trichy. Trichy – 620 002. Pan: Aljps 2284C (""यथ"/Respondent) (अपीलाथ"/Appellant) अपीलाथ" क" ओर से/Appellant By : Shri P. Thangaraj, Advocate ""यथ" क" ओर से/Respondent By : Ms. Anitha, Addl.Cit सुनवाई क" तारीख/Date Of Hearing : 03.04.2025 घोषणा क" तारीख/Date Of Pronouncement : 21.04.2025 आदेश /O R D E R Per S.R. Raghunatha, Am: This Appeal Of The Assessee Is Directed Against The Order Of The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi Dated 19.11.2024 For The Assessment Year 2017-18. 2. The Assessee Has Raised The Following Grounds Of Appeal:- I. The Order Of The Learned Assessment Officer Is Against The Law, Weightage Of Evidence & All Probabilities Of The Case.

For Appellant: Shri P. Thangaraj, AdvocateFor Respondent: Ms. Anitha, Addl.CIT

deposits have already been reflected as sales proceeds in the business accounts and subjected to tax. Treating these deposits as unexplained income results in double taxation. The appellant's records clearly demonstrate that the deposits Were part of routine business operations and not unexplained credits. Taxation of the same amount ... addition u/s.69A of the Act by considering the amount which has already been recorded in the books of accounts as revenue amounts to double taxation, which is not sustainable in law. Further, the ld.AR submitted that the acceptance of SBN was not prohibited as per the Specified Bank Notes (Cessation

Indira Veluri, Bangalore vs. Income Tax Officer, Ward-4(2)(3), Bangalore

In the result, the appeal is allowed

ITA 2513/BANG/2024[2021-2022]Status: DisposedITAT Bangalore21 Apr 2025AY 2021-2022

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2021-22

For Appellant: Sri Pavan Kumar, A.RFor Respondent: Sri Ganesh R Gale, Standing counsel for department
Section 250Section 253(5)

Rs.2,01,024/- and also paid tax on it at Rs.63,342/- and levying of additional tax of Rs.28,431/- is amounting to double taxation. In our opinion, the plea of the assessee is justified. The assessee has filed the copy of Form No.67 before Ld. CIT(A). He ought ... credit for foreign taxes. Article 24(4)(a) is relevant in the present context. Same is extracted below: “4. In the case of India, double taxation shall be avoided as follows: (a) the amount of Australian tax paid under the laws of Australia and in accordance with the provisions

Prathamik Krushi Coop Limited, Bagalkot vs. Income Tax Officer, Ward-1 & Tps, Bagalkot

In the result, the appeal of the assessee is hereby partly allowed for the statistical purposes

ITA 2344/BANG/2024[2017-18]Status: DisposedITAT Bangalore21 Apr 2025AY 2017-18

Bench: Shri Waseem Ahmedassessment Year: 2017-18

For Appellant: Shri Varun Bhat, CAFor Respondent: Shri Ganesh R Gale, Standing Counsel for Dept
Section 68

customers was already admitted as income and if the cash deposits are added under section 68 of the Act that will amount to double taxation once as sales and again as unexplained cash credit which is against the principles of taxation. It is also on record that the assessee

Shell International Petroleum Company Limited, Mumbai vs. Deputy Commissioner of Income Tax (Int Taxation)_4(2)(1), Mumbai

Accordingly we hold that the treatment of IT services is not in the nature of FTS and cannot be taxed in India. Ground No.25 to 27 are allowed and Ground No

ITA 3317/MUM/2023[2020-21]Status: DisposedITAT Mumbai21 Apr 2025AY 2020-21

Bench: Ms Padmavathy S, Am & Shri Raj Kumar Chauhan, Jm

For Respondent: Shri Vivek Perampurna, CIT-DR
Section 143(3)

purchases of computer software from the residents of Denmark and Finland. It was observed that such purchases would fall within the provisions of the Double Taxation Avoidance Agreement ("DTAA") entered between India and these countries. The Tribunal also observed that a co-ordinate Bench of the Tribunal in the assessee

Shell International Petroleum Company Limitedium, Mumbai vs. Dy Commissioner of Income Tax (International Taxation)-4(2)(1), Mumbai

Accordingly we hold that the treatment of IT services is not in the nature of FTS and cannot be taxed in India. Ground No.25 to 27 are allowed and Ground No

ITA 995/MUM/2022[2018-19]Status: DisposedITAT Mumbai21 Apr 2025AY 2018-19

Bench: Ms Padmavathy S, Am & Shri Raj Kumar Chauhan, Jm

For Respondent: Shri Vivek Perampurna, CIT-DR
Section 143(3)

purchases of computer software from the residents of Denmark and Finland. It was observed that such purchases would fall within the provisions of the Double Taxation Avoidance Agreement ("DTAA") entered between India and these countries. The Tribunal also observed that a co-ordinate Bench of the Tribunal in the assessee

Shell International Petroleum Company Ltd., Mumbai vs. DCIT (It) 4(2)(1), Mumbai

Accordingly we hold that the treatment of IT services is not in the nature of FTS and cannot be taxed in India. Ground No.25 to 27 are allowed and Ground No

ITA 2307/MUM/2022[2019-20]Status: DisposedITAT Mumbai21 Apr 2025AY 2019-20

Bench: Ms Padmavathy S, Am & Shri Raj Kumar Chauhan, Jm

For Respondent: Shri Vivek Perampurna, CIT-DR
Section 143(3)

purchases of computer software from the residents of Denmark and Finland. It was observed that such purchases would fall within the provisions of the Double Taxation Avoidance Agreement ("DTAA") entered between India and these countries. The Tribunal also observed that a co-ordinate Bench of the Tribunal in the assessee

M/S. Shell Interational Petroleum Co. Ltd., Mumbai vs. Dy CIT (International Taxation)-4(2)(1), Mumbai

ITA 1244/MUM/2021[2017-18]Status: DisposedITAT Mumbai21 Apr 2025AY 2017-18

Bench: Ms Padmavathy S, Am & Shri Raj Kumar Chauhan, Jm

Section 143(3)Section 234ASection 271(1)(c)

purchases of computer software from the residents of Denmark and Finland. It was observed that such purchases would fall within the provisions of the Double Taxation Avoidance Agreement ("DTAA") entered between India and these countries. The Tribunal also observed that a co-ordinate Bench of the Tribunal in the assessee

M/S Shell International Petroleum Company Ltd., Mumbai vs. Dy CIT (It)- 4 (2)(1), Mumbai

ITA 7499/MUM/2019[2016-17]Status: DisposedITAT Mumbai21 Apr 2025AY 2016-17

Bench: Ms Padmavathy S, Am & Shri Raj Kumar Chauhan, Jm

For Appellant: Respondent)For Respondent: Shri Vivek Perampurna, CIT-DR
Section 143(3)Section 271(1)(c)

purchases of computer software from the residents of Denmark and Finland. It was observed that such purchases would fall within the provisions of the Double Taxation Avoidance Agreement ("DTAA") entered between India and these countries. The Tribunal also observed that a co-ordinate Bench of the Tribunal in the assessee

Jayanthi Rajagounder, Chennai vs. ITO, Ncw-19(4), Chennai

In the result, the appeal filed by the assessee is allowed

ITA 3146/CHNY/2024[2017-18]Status: DisposedITAT Chennai17 Apr 2025AY 2017-18

Bench: Shri George George K, Hon’Ble & Shri S.R. Raghunatha, Hon’Bleआयकर अपीलसं./Ita Nos.: 3146/Chny/2024 िनधा"रण वष" / Assessment Year: 2017-18 Smt. Jayanthi Rajagounder, The Income Tax Officer, No.F-1, First Floor, V. Non-Corporate Ward 19(4), Seenivasam Flat No.9, Chennai - 34. Durairaj Street, Palavanthangal, Chennai – 600 061. [Pan:Ahspj 9904F] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" की ओर से/Appellant By : Shri K.B. Muralidharan, Ca ""थ" की ओर से/Respondent By : Ms. Gouthami Manivasagam, Jcit सुनवाई क" तार"ख/Date Of Hearing : 26.02.2025 घोषणा क" तार"ख/Date Of Pronouncement : 17.04.2025 आदेश /O R D E R

For Appellant: Shri K.B. Muralidharan, CAFor Respondent: Ms. Gouthami Manivasagam, JCIT
Section 115BSection 69A

offered to tax in his return of income filed. The estimation of commission on these credits in the hands of assessee amounts to double taxation, therefore we are of the considered view that the same needs to be deleted and ordered accordingly. 6.1 Further, the AO had made an addition

Sree Balaji Bullions, Salem vs. DCIT, Circle-1(1), Salem

In the result, appeal filed by the assessee is allowed

ITA 2302/CHNY/2024[2017-18]Status: DisposedITAT Chennai17 Apr 2025AY 2017-18

Bench: Shri George George K, Hon’Ble & Shri S.R. Raghunatha, Hon’Bleआयकर अपील सं./Ita Nos.: 2302/Chny/2024 िनधा"रण वष" / Assessment Year: 2017-18 Sree Balaji Bullions, Dy. Commissioner Of 22/43, Vasagasalai, Income Tax, Shevapet, V. Circle 1(1), Salem– 636002. Salem. [Pan: Aasfs-5947-E] (""यथ"/Respondent) (अपीलाथ"/Appellant) : Shri.S.Sridhar, Advocate अपीलाथ" क" ओर से/Appellant By & N.Arjun Raj, Advocate ""थ" की ओर से/Respondent By : Ms.T.M.Suganthamala, Cit सुनवाई क" तार"ख/Date Of Hearing : 25.02.2025 घोषणा क" तार"ख/Date Of Pronouncement : 17.04.2025 आदेश /O R D E R

For Respondent: Ms.T.M.Suganthamala, CIT
Section 115BSection 69A

opinion that when the sale has been reflected in the books of accounts and offered to tax, adding the same again would amount to double taxation, which is impermissible in law. The cash sales made by the assessee have been credited in the books of accounts and the same form ... assessee. When the sales has been reflected in the books of accounts and offered to tax, adding the same would amount to double taxation which is impermissible in law. The books are subjected to Tax Audit u/s 44AB and the assessee has maintained quantitative details of the stock-intrade

Oakton Global Technology Services Centre (I) Private Limited, Hyderabad vs. Dy. Commissioner of Income Tax, Circle-16(2), Hyderabad

In the result, the appeal of the assessee in ITA No

ITA 32/HYD/2019[2014-15]Status: DisposedITAT Hyderabad16 Apr 2025AY 2014-15

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

For Appellant: Shri Ravi Bharadawaj, C.AFor Respondent: Shri B. Bala Krishna, CIT-DR
Section 143(3)Section 92B

loan is to be re-paid normally determines the rate of return on the money lent, i.e. the rate of interest. Klaus Vogel on Double Taxation Conventions (Third Edition) under Article 11 in paragraph 115 states as under:— "The existing differences in the levels of interest rates do not depend

Oakton Global Technology Services Centre (India) Private Limited, Hyderabad vs. Deputy Commissioner of Income Tax, Circle-16(2), Hyderabad

In the result, the appeal of the assessee in ITA No

ITA 2130/HYD/2017[2013-14]Status: DisposedITAT Hyderabad16 Apr 2025AY 2013-14

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

For Appellant: Shri Ravi Bharadawaj, C.AFor Respondent: Shri B. Bala Krishna, CIT-DR
Section 143(3)Section 92B

loan is to be re-paid normally determines the rate of return on the money lent, i.e. the rate of interest. Klaus Vogel on Double Taxation Conventions (Third Edition) under Article 11 in paragraph 115 states as under:— "The existing differences in the levels of interest rates do not depend

Aditya Somani, Hooghly vs. Income Tax Officer, Ward 34(1), Kolkata

In the result, the appeal filed by the assessee is allowed

ITA 1897/KOL/2024[2021-22]Status: DisposedITAT Kolkata16 Apr 2025AY 2021-22

Bench: Shri Rajesh Kumar&Shri Pradip Kumar Choubey]

Section 1Section 139Section 143(1)Section 154Section 234BSection 6Section 90

result, the appeal filed by the assessee is allowed." 9. The relevant extracts of Article 24 of the Treaty on Relief From Double Taxation is reproduced below for ready reference: 6 I.T.A. No. 1897/Kol/2024 Assessment Year: 2021-22 Aditya Somani. 11. Since the facts of the case at hand each

Bosch Global Software Technologies Private Limited, Bengaluru vs. Assistant Commissioner of Income Tax, Circle-2(1)(1), Bangalore

In the result, the appeal of the assessee is hereby partly allowed for statistical purposes

ITA 1696/BANG/2024[2016-17]Status: DisposedITAT Bangalore16 Apr 2025AY 2016-17

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2016-17

For Appellant: and Smt. Pratibha R – AdvocateFor Respondent: Smt. Nandini Das, CIT
Section 10ASection 32(1)(iia)

proportionate credit, and does not, in any case, specifically provide for the full foreign tax credit. A full tax credit, which goes beyond eliminating double taxation of an income, actually ends up subsidizing the foreign exchequer, to the extent that the taxes paid to the foreign exchequer are allowed ... discharge exclusive domestic tax liability, rather than eliminating double taxation of an income, and that is the reason that even in the solitary full credit situation visualized in the Indian tax treaties, in the Indo Namibia tax treaty (supra), it's one-way traffic inasmuch as while India

Assistant Commissioner of Income Tax, C-1(1)(1), Bangalore vs. Bangalore International Airport Limited, Bangalore

In the result, the cross objection of the assessee is hereby partly allowed

ITA 1109/BANG/2024[2020-21]Status: DisposedITAT Bangalore16 Apr 2025AY 2020-21

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri T. Suryanarayana, AdvocateFor Respondent: Smt. Nandini Das, CIT-DR
Section 80I

return of income. However, the AO wrongly disallowed the same again in the assessment order and added to the total income which amount to double taxation of the same amount. 11. The learned CIT(A) regarding disallowance of part of income under the head non-aeronautical found that identical disallowances ... claimed as deduction by the assessee. Therefore, the disallowance of the same by the AO amount to double taxation. Hence, the addition made for Rs. 16,13,28,744/- was deleted. 14. Regarding the interest income of Rs. 33,93,27,137/- the learned CIT(A) noted that the assessee

Assistant Commissioner of Income Tax, C-1(1)(1), Bangalore vs. Bangalore International Airport Limited, Bangalore

ITA 1108/BANG/2024[2018-19]Status: DisposedITAT Bangalore16 Apr 2025AY 2018-19

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri T. Suryanarayana, AdvocateFor Respondent: Smt. Nandini Das, CIT-DR
Section 143(4)Section 80I

return of income. However, the AO wrongly disallowed the same again in the assessment order and added to the total income which amount to double taxation of the same amount. 11. The learned CIT(A) regarding disallowance of part of income under the head non-aeronautical found that identical disallowances ... Rs.16,13,28,744/- was not claimed as deduction by the assessee. Therefore, the disallowance of the same by the AO amount to double taxation. Hence, the addition made for Rs. 16,13,28,744/- was deleted. 14. Regarding the interest income of Rs.33,93,27,137/- the learned