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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

ACIT Circle 1(1) & Tps, Mangaluru vs. M/S the South Canara District Central Co-Operative Bank Limited, Mangaluru

In the result, the appeal of the revenue is hereby dismissed

ITA 2332/BANG/2024[2017-18]Status: DisposedITAT Bangalore04 Mar 2025AY 2017-18

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Smt. Sheetal Borkar – AdvocateFor Respondent: Ms. Nandini Das, CIT (DR)
Section 145Section 22(1)

then setoff to the extent of amount offered on cash basis in current year shall allowed to the assessee otherwise same will amount to double taxation. 18.1.4. Before parting, it is imperative to note that under the concept of accrual system of accounting viz a viz cash system of accounting ... assessee cannot be applied for the year under consideration. 18.2.5. Before parting, it is equally important to note that there should not be any double taxation to the income of the assessee merely because of change in the method of accounting from cash to accrual for the investment which

ACIT Circle1(1)& Tps, Mangaluru vs. M/S South Kanara District Central Co-Operative Bank Ltd, Mangaluru

In the result, the appeal of the revenue is hereby dismissed

ITA 2331/BANG/2024[2016-17]Status: DisposedITAT Bangalore04 Mar 2025AY 2016-17

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Smt. Sheetal Borkar – AdvocateFor Respondent: Ms. Nandini Das, CIT (DR)
Section 145Section 22(1)

then setoff to the extent of amount offered on cash basis in current year shall allowed to the assessee otherwise same will amount to double taxation. 18.1.4. Before parting, it is imperative to note that under the concept of accrual system of accounting viz a viz cash system of accounting ... assessee cannot be applied for the year under consideration. 18.2.5. Before parting, it is equally important to note that there should not be any double taxation to the income of the assessee merely because of change in the method of accounting from cash to accrual for the investment which

M/S the South Canara District Central Co-Op Bank Ltd, Mangaluru vs. The Deputy Commissioner of Income Tax, Central Circle - 1, Mangalore

In the result, the appeal of the revenue is hereby dismissed

ITA 219/BANG/2023[2018-19]Status: DisposedITAT Bangalore04 Mar 2025AY 2018-19

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Smt. Sheetal Borkar – AdvocateFor Respondent: Ms. Nandini Das, CIT (DR)
Section 145Section 22(1)

then setoff to the extent of amount offered on cash basis in current year shall allowed to the assessee otherwise same will amount to double taxation. 18.1.4. Before parting, it is imperative to note that under the concept of accrual system of accounting viz a viz cash system of accounting ... assessee cannot be applied for the year under consideration. 18.2.5. Before parting, it is equally important to note that there should not be any double taxation to the income of the assessee merely because of change in the method of accounting from cash to accrual for the investment which

M/S the South Canara District Central Co-Op Bank Ltd, Mangaluru vs. The Deputy Commissioner of Income Tax, Central Circle - 1, Mangalore

In the result, the appeal of the revenue is hereby dismissed

ITA 218/BANG/2023[2017-18]Status: DisposedITAT Bangalore04 Mar 2025AY 2017-18

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Smt. Sheetal Borkar – AdvocateFor Respondent: Ms. Nandini Das, CIT (DR)
Section 145Section 22(1)

then setoff to the extent of amount offered on cash basis in current year shall allowed to the assessee otherwise same will amount to double taxation. 18.1.4. Before parting, it is imperative to note that under the concept of accrual system of accounting viz a viz cash system of accounting ... assessee cannot be applied for the year under consideration. 18.2.5. Before parting, it is equally important to note that there should not be any double taxation to the income of the assessee merely because of change in the method of accounting from cash to accrual for the investment which

M/S the South Canara District Central Co-Op Bank Ltd, Mangaluru vs. The Deputy Commissioner of Income Tax, Central Circle - 1, Mangalore

In the result, the appeal of the revenue is hereby dismissed

ITA 217/BANG/2023[2016-17]Status: DisposedITAT Bangalore04 Mar 2025AY 2016-17

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Smt. Sheetal Borkar – AdvocateFor Respondent: Ms. Nandini Das, CIT (DR)
Section 145Section 22(1)

then setoff to the extent of amount offered on cash basis in current year shall allowed to the assessee otherwise same will amount to double taxation. 18.1.4. Before parting, it is imperative to note that under the concept of accrual system of accounting viz a viz cash system of accounting ... assessee cannot be applied for the year under consideration. 18.2.5. Before parting, it is equally important to note that there should not be any double taxation to the income of the assessee merely because of change in the method of accounting from cash to accrual for the investment which

Shah Rukh Khan, Mumbai vs. DCIT Central Circle 4(2), Mumbai

In the result, the appeal by the assessee is allowed

ITA 6312/MUM/2024[A. Y. 2012-13 ]Status: DisposedITAT Mumbai04 Mar 2025

Bench: Shri Sandeep Singh Karhailshri Girish Agrawalshah Rukh Khan, 44, Mannat, Bj Road, Bandstand, Bandra, Mumbai - 400050 Pan: Aahpk3293L ……………. Appellant V/S Dcit, Central Circle – 4(2) Kautilya Bhavan, Bandra Kurla Complex, Bandra East, ……………. Respondent Mumbai - 400050 Maharashtra

For Appellant: Shri Aditya AjgaonkarFor Respondent: Ms. Kavitha Kaushik, Sr. DR
Section 148Section 250

Income-tax Act, 1961, in a clear case of 'change of opinion' by the Assessing Officer as the subject of double taxation relief claimed had already been examined by the Assessing Officer in the original 143(3) proceedings. He further erred in concluding that the Appellant has not disclosed fully ... matter and in law, the Learned Commissioner Income Tax (Appeal) erred in upholding the validity of the reassessment proceedings and the denial of the double taxation relief of Rs.1,40,00,000/- withheld at source in the UK. Infact, for the same Assessment Year prior to the issue of notice

Deputy Commissioner of Income Tax(International Taxation) Circle-2(2) Bengaluru, Bangalore vs. U L India Private Limited, Bangalore

In the result, the appeals filed by the assessee are allowed for statistical purposes and the appeal filed by revenue stands dismissed

ITA 29/BANG/2024[2012-13]Status: DisposedITAT Bangalore03 Mar 2025AY 2012-13

Bench: Shri Waseem Ahmed & Shri Prakash Chand Yadav

For Appellant: Sri Ketan Ved, A.RFor Respondent: Ms. Neera Malhotra, D.R
Section 195Section 201(1)Section 250

taxes due on such income declared in the return of income, and accordingly the demand under section 201(1) of the Act results in double taxation and thus ought to be reduced. IT(IT)A No.1135/Bang/2023 UL LLC, US ITA No.1136/Bang/2023 & ITA No.29/Bang/2024 UL India Private Limited, Bangalore

M/S. Ul India Private Limited, Bengaluru vs. Assistant Commissioner of Income Tax, (International Taxation), Circle-2(2), Bengaluru

In the result, the appeals filed by the assessee are allowed for statistical purposes and the appeal filed by revenue stands dismissed

ITA 1136/BANG/2023[2012-13]Status: DisposedITAT Bangalore03 Mar 2025AY 2012-13

Bench: Shri Waseem Ahmed & Shri Prakash Chand Yadav

For Appellant: Sri Ketan Ved, A.RFor Respondent: Ms. Neera Malhotra, D.R
Section 195Section 201(1)Section 250

taxes due on such income declared in the return of income, and accordingly the demand under section 201(1) of the Act results in double taxation and thus ought to be reduced. IT(IT)A No.1135/Bang/2023 UL LLC, US ITA No.1136/Bang/2023 & ITA No.29/Bang/2024 UL India Private Limited, Bangalore

Satia Industries Limited, Muktsar, Punjab vs. DCIT, ACIT Circle 1, Bathinda

In the result, the appeal is partly allowed

ITA 527/ASR/2024[2020-21]Status: DisposedITAT Amritsar28 Feb 2025AY 2020-21

Bench: Shri Udayan Das Gupta & Shri Krinwant Sahayआयकरअपीलसं./Ita No. 527/Asr/2024 िनधा"रणवष" / Assessment Year : 2020-21

For Appellant: S/Shri Sudhir SehgalFor Respondent: Shri K. Mehboob Ali Khan, CIT DR
Section 143(2)Section 143(3)Section 144C(13)Section 144C(5)Section 80

books of accounts and as such, taxing the same amount in the year under consideration tantamount to double taxation. 32. The Id. Counsel has also brought on record different case laws which are as under: - (a) [2023] 157 taxmann.com 547 (Kolkata - Trib.) in the ITAT KOLKATA BENCH 'C Harmuny Entertainment ... itself has deducted the same amount in the next years return of income, therefore, disallowing the same in this year would be tantamount to double taxation. Accordingly, Assessee’s appeal on this ground is allowed. 35. In the result, the appeal is partly allowed. Order pronounced on 28th

Anees Begum, Hyderabad vs. ACIT., Central Circle-2(3), Hyderabad

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

ITA 971/HYD/2024[2019-20]Status: DisposedITAT Hyderabad28 Feb 2025AY 2019-20

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.971/Hyd/2024 (िनधा"रण वष"/Assessment Year: 2019-20) Smt. Anees Begum Vs. Acit Hyderabad Central Circle 2(3) Pan:Bbhb8220J Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri P Murali Mohan Rao, Ca राज" व "ारा/Revenue By:: Shri Spg Mudaliar, Dr सुनवाई की तारीख/Date Of Hearing: 24/12/2024 घोषणा की तारीख/Pronouncement: 28/02/2025 आदेश/Order

For Appellant: Shri P Murali Mohan Rao, CAFor Respondent: : Shri SPG Mudaliar, DR
Section 132Section 142(1)Section 143(2)Section 144

total bank credits cannot be considered as business turnover of the assessee for the purpose of estimation of profits. Further, it amounts to double taxation when the entire credits in the bank account is treated as turnover, as some of the credits were already taxed in the previous year

Arthi Baliga, Chennai vs. ACIT, NFAC, Delhi

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

ITA 1559/CHNY/2024[2017-18]Status: DisposedITAT Chennai28 Feb 2025AY 2017-18

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. No.1559/Chny/2024 िनधा"रण वष"/Assessment Year: 2017-18 Arthi Baliga, Vs. The Principal Commissioner Of No. 15, Flat No. 3-C, Coral Woods Income Tax, Chennai-4, Apartment, Sri Ram Nagar, South Chennai. Street, Alwarpet, Chennai 600 018. [Pan:Bkjpb5416P] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri Ravi Kannan, Advocate & Shri Varun Ranganathan, Advocate ""थ" की ओर से/Respondent By : Shri Nilay Baran Som, Cit सुनवाई की तारीख/ Date Of Hearing : 05.12.2024 घोषणा की तारीख /Date Of Pronouncement : 28.02.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 19.03.2024 Passed By The Ld. Principal Commissioner Of Income Tax, Chennai-4, Chennai For The Assessment Year 2017-18 Under Section 263 Of The Income Tax Act, 1961 [“Act” In Short].

For Appellant: Shri Ravi Kannan, Advocate &For Respondent: Shri Nilay Baran Som, CIT
Section 143(3)Section 147Section 148Section 263

offered by the firm, the interest of the revenue stands protected and any further tax in would result 12 I.T.A. No.1559/Chny/24 in double taxation. The assessment order could not be said to be prejudicial to the interest of revenue because, if the capital gains are taxed in the hands ... Firm vide its Return of Income dated 31/03/2017 (at Page No. 203 of the ADP). Therefore, any further tax would only amount to double taxation, as there is no prejudice caused to the interest the revenue, the proceedings lack jurisdiction and referred to section 112 of the Income

Smt. Jayanthi Seeman, Chennai vs. ITO, Ncw - 1 (2), Chennai

ITA 773/CHNY/2020[2013-14]Status: DisposedITAT Chennai28 Feb 2025AY 2013-14

Bench: Shri Aby T. Varkey, Hon'Ble & Shri S.R.Raghunatha, Hon'Bleआयकर अपील सं/.Ita Nos.: 770, 771, 772 & 773/Chny/2020 निर्धा रणवर्ष / Assessment Years: 2010-11, 2011-12, 2012-13 & 2013-14 Smt. Jayanthi Seeman, C/O. Aparna Nandakumar, Advocate & Tax Consultant, J Nandakumar & Poojesh J (Advocates) No. 6, Ramakrishna Street, T.Nagar, Chennai – 600 017. [Pan: Acypj-0739-K] (अपीलार्थी/Assessee) अपीलार्थीकीओरसे/Assessee By प्रत्यर्थीकीओरसे/Respondent By सुनवाईकीतारीख/Date Of Hearing घोषणाकीतारीख/Date Of Pronouncement Income Tax Officer, Non-Corporate Ward -1(2), Chennai. (प्रत्यर्थी/Respondent) Shri. Y. Sridhar, Fca Shri. R. Raghupathy, Addl.Cit 20.02.2025 28.02.2025 आदेश/Order Per S. R. Raghunatha: These Appeals Filed By The Assessee Are Directed Against The Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals) - 2, Chennai, All Dated 30.07.2020 For The Assessment Years 2010-11 To 2013-14.

Section 132Section 143(3)Section 69

आयकर अपीलीय अधिकरण “ए” न्यायपीठ चेन्नई में। IN THE INCOME TAX APPELLATE TRIBUNAL `A' BENCH, CHENNAI श्री एबी टी. वर्की

Smt. Jayanthi Seeman, Chennai vs. ITO, Ncw - 1 (2), Chennai

ITA 772/CHNY/2020[2012-13]Status: DisposedITAT Chennai28 Feb 2025AY 2012-13

Bench: Shri Aby T. Varkey, Hon'Ble & Shri S.R.Raghunatha, Hon'Bleआयकर अपील सं/.Ita Nos.: 770, 771, 772 & 773/Chny/2020 निर्धा रणवर्ष / Assessment Years: 2010-11, 2011-12, 2012-13 & 2013-14 Smt. Jayanthi Seeman, C/O. Aparna Nandakumar, Advocate & Tax Consultant, J Nandakumar & Poojesh J (Advocates) No. 6, Ramakrishna Street, T.Nagar, Chennai – 600 017. [Pan: Acypj-0739-K] (अपीलार्थी/Assessee) अपीलार्थीकीओरसे/Assessee By प्रत्यर्थीकीओरसे/Respondent By सुनवाईकीतारीख/Date Of Hearing घोषणाकीतारीख/Date Of Pronouncement V. Income Tax Officer, Non-Corporate Ward -1(2), Chennai. (प्रत्यर्थी/Respondent) Shri. Y. Sridhar, Fca Shri. R. Raghupathy, Addl.Cit 20.02.2025 28.02.2025 आदेश/Order Per S. R. Raghunatha: These Appeals Filed By The Assessee Are Directed Against The Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals) - 2, Chennai, All Dated 30.07.2020 For The Assessment Years 2010-11 To 2013-14.

Section 132Section 143(3)Section 69

आयकर अपीलीय अधिकरण “ए” न्यायपीठ चेन्नई में। IN THE INCOME TAX APPELLATE TRIBUNAL `A' BENCH, CHENNAI श्री एबी टी. वर्की

Ambika Trading Corporation, Mumbai vs. DCIT 24(1), Mumbai

In the result the appeals filed by the assessee for both assessment years stands partly allowed

ITA 6058/MUM/2024[2015-16]Status: DisposedITAT Mumbai28 Feb 2025AY 2015-16

Bench: Smt. Beena Pillai () & Shri Omkareshwar Chidara ()

Section 139(1)Section 147Section 148

this income already declared in the return of income filed on 25.08.2014 for AY 2014-15 under the old PAN AAGFA2653R to avoid any double taxation. The ground of appeal no. 2 taken by the appellant is, thus, partly allowed. 3.1. On the issue of addition under section

Ambika Trading Corporation, Mumbai vs. DCIT 24(1), Mumbai

In the result the appeals filed by the assessee for both assessment years stands partly allowed

ITA 6057/MUM/2024[2014-15]Status: DisposedITAT Mumbai28 Feb 2025AY 2014-15

Bench: Smt. Beena Pillai () & Shri Omkareshwar Chidara ()

Section 139(1)Section 147Section 148

this income already declared in the return of income filed on 25.08.2014 for AY 2014-15 under the old PAN AAGFA2653R to avoid any double taxation. The ground of appeal no. 2 taken by the appellant is, thus, partly allowed. 3.1. On the issue of addition under section

Prevision Project Management Systems Pvt Ltd, Mumbai vs. Income Tax Officer -14(2)(4), Mumubai

In the result, appeal filed by the assessee stands allowed for

ITA 5799/MUM/2024[2012-13]Status: DisposedITAT Mumbai28 Feb 2025AY 2012-13

Bench: Smt. Beena Pillai ()

Section 147Section 69ASection 69C

appellant and in law Ld. NFAC has erred in adding the same amount twice to the income of the applicant leading to double taxation. 5) That the impugned order being contrary to law, evidence, and facts of the case may kindly be set aside, amended, and modified in the light

Unni Krishnan Vadakkedath Sugathan, Mumbai vs. Income Tax Officer 4 (3)(1), Bandra

In the result the appeal filed by the Assessee stands allowed

ITA 3604/MUM/2024[2013-14]Status: DisposedITAT Mumbai28 Feb 2025AY 2013-14

Bench: Shri Narender Kumar Choudhry, Jm & Shri Omkareshwar Chidara, Am

For Appellant: Shri Kirit MehtaFor Respondent: Shri Krishna Kumar (Sr. DR)
Section 143(3)Section 17Section 250Section 271(1)(c)Section 90Section 90A

account of employees' stock option to the tune of Rs. 20,44,855/- as per section 17 of the Act and/or Double Taxation Avoidance Agreement between India and UAE (DTAA) has been disallowed. 3. The Assessee, being aggrieved, challenged the said addition before the then CIT(A), who vide order

Loparex Holding Bv, Mumbai vs. ACIT, International Taxation, Circle-3(1)(2), Mumbai

In the result the appeal filed by the assessee stands dismissed

ITA 4813/MUM/2023[2021-22]Status: DisposedITAT Mumbai28 Feb 2025AY 2021-22

Bench: Smt. Beena Pillai () & Shri Renu Jauhri ()

Section 234DSection 270ASection 274

justify its claim of taxing dividend in India at 5%. In response, the assessee submitted that, as per Article 10 of the India-Netherlands Double Taxation Avoidance Agreement (hereinafter referred to as DTAA), taxes on dividend can be levied in the country in which the company paying such dividend resident ... that section 90 is specifically intended to enable and empower the Central Government to issue a notification for implementation of the terms of a double taxation avoidance agreement. When that happens, the provisions of such an agreement, with respect to cases to which where they apply, would operate even

Manojbhai Arvindbhai Parekh, Rajkot vs. Assistant Commissioner of Income Tax, Circle - 2(1), Rajkot

In the result, appeal filed by the assessee, is partly allowed in above terms

ITA 385/RJT/2023[2017-18]Status: DisposedITAT Rajkot27 Feb 2025AY 2017-18

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 385 /Rjt/2023 ("नधा"रण वष"/Assessment Year: (2017-18) Manojbhai Arvindbhai Parekh The Acit Of I. T. Circle – 2(1), Shreeji Giriraj Trading, 19-Giriraj Vs. Rajkot – 360001 Chamber, Old Gadhiwas Soni Bazar, Rajkot – 360001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Acypp1471C (अपीलाथ"/Assessee) (""यथ"/Respondent)

For Appellant: Shri Chetan Agarwal, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr.DR
Section 115BSection 142(1)Section 143(1)Section 143(2)Section 143(3)Section 68

thereon, therefore, the same sales should not be taxable, by the assessing officer, again in the hands of the assessee, as it would be double taxation. Therefore, ld. Counsel contended that addition made by the assessing officer should be deleted. 13. On the other hand ... books of accounts and offered for tax. Hence, the addition of the same amount u/s 68 as alleged unexplained cash credit resulted in double taxation of the same income which is completely impermissible under the law.The identical situation has come up before the Courts and Tribunals on several occasions

Matrix Publicities and Media India Private Limited, Mumbai vs. DCIT - 16(1), Mumbai

The appeal of the assessee is allowed

ITA 6769/MUM/2024[AY 2019-20]Status: DisposedITAT Mumbai27 Feb 2025

Bench: Shri Amit Shukla, Jm & Ms Padmavathy S, Am

For Respondent: Shri R.R. Makwana, Addl. CIT
Section 143(1)Section 154Section 244A

Appellant twice i.e. once in the year of accrual of income and again in the year of raising invoice leading to double taxation of the same income and thereby leading to violating the principles of natural justice.” 2. The assessee is a company and has acquired the exclusive rights