JM FINANCIAL LTD,MUMBAI vs. DCIT 4(3), MUMBAI
The appeal of the assessee is allowed and the appeal of the revenue is dismissed
ITA 3987/MUM/2015[2008-09]Status: DisposedITAT Mumbai04 Aug 2023AY 2008-09
Bench: Shri Aby T Varkey () & Ms. Padmavathy S. ()
Section 143(3)
after considering the Vodafone International Holdings B.V. vs UOI [(2012) 341 ITR 1]
that the consideration is to be taxed in terms of section 28(2) of the Income-tax
Act, 1961 for the reason that –
Case of Vodafone was for taxability of capital gains in India when non-resident