THR INFRASTRUCTURE PTE LTD,GURGAON vs. DCIT, CIR.-3(1)(1), INTL TAX, NEW DELHI
In the result, the appeal of the assessee is allowed
ITA 1915/DEL/2022[201-18]Status: DisposedITAT Delhi12 May 2023
Bench: Sh. Saktijit Deydr. B. R. R. Kumar
For Appellant: Sh. Ajay Vohra, Sr. AdvFor Respondent: Sh. Gangadhar Panda, CIT-DR
Section 143(3)
listed company on a recognized stock exchange of Singapore. In this connection, the Assessee seeks to draw support from the provisions of section 2(18)(B)(c) of the Act, which provides that the wholly owned subsidiary of a listed company would be regarded as "a company in which public ... regarded as a listed company on a recognized stock exchange of Singapore. Further, assessee in support drew a reference of provisions of section 2(18)(B)(c) of the Act and placed reliance on decision of IT AT, Pune bench in the case of Daimler
Chrysler India