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“Section 5(2)(1)”

Section References (mined)Section 5Section 5(2)(1)2 judgments

SIS LIVE,NEW DELHI vs. ACIT, CIRCLE-3(1)(2), INTERNATIONAL TAXATION, NEW DELHI

In the result, the appeal is partly allowed

ITA 2146/DEL/2022[2019-20]Status: DisposedITAT Delhi30 May 2023AY 2019-20

Bench: Shri G.S. Pannu, Hon’Ble & Shri Saktijit Deyassessment Year: 2018-19 & Assessment Year: 2019-20 Sis Live, Vs. Assistant Commissioner Of 4Th Floor, Statesman House Income Tax, Building, Barakhamba Road, Circle-3(1)(2), International Connaught Place, Taxation, New Delhi New Delhi Pan :Abrfs4787L (Appellant) (Respondent)

Section 143(3)Section 144CSection 144C(13)Section 9

income was also received outside India. Therefore, it cannot be said to have been received or deemed to be received in India under section 5(2)(1) of the Act. More so, when the interest income has no nexus with India. He submitted, once the interest income does not accrue

SIS LIVE ,NEW DELHI vs. ACIT CIRCLE-3(1)(2),INTERNATIONAL TAXATION, NEW DELHI

In the result, the appeal is partly allowed

ITA 2145/DEL/2022[2018-19]Status: DisposedITAT Delhi30 May 2023AY 2018-19

Bench: Shri G.S. Pannu, Hon’Ble & Shri Saktijit Deyassessment Year: 2018-19 & Assessment Year: 2019-20 Sis Live, Vs. Assistant Commissioner Of 4Th Floor, Statesman House Income Tax, Building, Barakhamba Road, Circle-3(1)(2), International Connaught Place, Taxation, New Delhi New Delhi Pan :Abrfs4787L (Appellant) (Respondent)

Section 143(3)Section 144CSection 144C(13)Section 9

income was also received outside India. Therefore, it cannot be said to have been received or deemed to be received in India under section 5(2)(1) of the Act. More so, when the interest income has no nexus with India. He submitted, once the interest income does not accrue