QUASAR MEDIA PRIVATE LIMITED,NEW DELHI vs. ACIT CIRCLE-20(2), NEW DELHI
Appeal are allowed and the remaining grounds being consequential in nature follow the event
ITA 7088/DEL/2019[2015-16]Status: DisposedITAT Delhi10 Mar 2023AY 2015-16
Bench: Sh. Kul Bharatdr. B. R. R. Kumar
For Appellant: Sh. Anil Bhalla, CAFor Respondent: Sh. Sanjay Kumar, Sr. DR
Section 195Section 40Section 5Section 9(1)Section 9(1)(b)Section 9(1)(i)Section 9(1)(vi)
DTAA and therefore Article 12 as appearing in the treaty stands diluted and has to be read with the Explanation 5 to Section 9(1)(b) of the Act.”
3. The assessee company incurred various expenses which were payable to foreign entities
(non-residents) which includes payment to NTT America
