“Section 90(1)(a)(i)”

Section References (mined)Section 90Section 90(1)(a)(i)6 judgments

PRADEEP WIG,NEW DELHI vs. ACIT CENTRAL CIRCLE-5, NEW DELHI

The appeals of the Revenue are dismissed

ITA 406/DEL/2021[2012-13]Status: DisposedITAT Delhi29 Apr 2025AY 2012-13

Bench: Shri M. Balaganesh & Shri Anubhav Sharma

taxed” cannot be construed to mean “shall be taxable only in the resident state”, unless it is expressly stated. Provisions of section 90(1)(a)(i) is clearly applicable to the facts of the case.” 44. Then we find that the ld. tax authorities below have considered the appellants/assessee

M/S WIPRO LIMITED ,BNAGALORE vs. JOINT COMMISSIONER OF INCOME TAX SPECIAL RANGE-7 , BANGALORE

Appeals is partly allowed for statistical purposes as in earlier orders of this Tribunal

ITA 3115/BANG/2018[2014-15]Status: DisposedITAT Bangalore13 Jun 2024AY 2014-15

For Appellant: Sri Dhyan Chinnappa, Sr. A.R. and Sri Sandeep Huilgol, A.RFor Respondent: Ms. Neera Malhotra, D.R

Section 37(1)Section 90Section 90(1)(b)Section 91

this background, when we notice section 90 of the Act-relief from double taxation is granted in the following circumstances. Firstly, section 90(1)(b) of the Act speaks about avoidance of double taxation, i.e., the Central Government may enter into an agreement with the Government of any country ... benefit of double taxation relief by way of avoidance is granted to the assessee in both the countries. 38. Secondly, under section 90(1)(a)(i) of the Act, once such assessee has paid Income-tax, under the Act as well as the tax in the other country, by such

M/S. WIPRO LIMITED,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX,CIRCLE-7(1)(2), BANGALORE

ITA 492/BANG/2017[2012-13]Status: DisposedITAT Bangalore13 Jun 2024AY 2012-13

For Appellant: Sri Dhyan Chinnappa, Sr. A.R. andFor Respondent: Ms. Neera Malhotra, D.R

Section 37(1)Section 90Section 91

this background, when we notice section 90 of the Act-relief\nfrom double taxation is granted in the following circumstances.\nFirstly, section 90(1)(b) of the Act speaks about avoidance of\ndouble taxation, i.e., the Central Government may enter into an\nagreement with the Government of any country ... this background, when we notice section 90 of the Act-relief\nfrom double taxation is granted in the following circumstances.\nFirstly, section 90(1)(b) of the Act speaks about avoidance of\ndouble taxation, i.e., the Central Government may enter into an\nagreement with the Government of any country

M/S WIPRO LIMITED ,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-7(1)(2), BANGALORE

Appeals is allowed

ITA 2851/BANG/2017[2013-14]Status: DisposedITAT Bangalore13 Jun 2024AY 2013-14

Section 37(1)Section 90Section 91

this background, when we notice section 90 of the Act—relief\nfrom double taxation is granted in the following\ncircumstances.\nFirstly, section 90(1)(b) of the Act speaks about avoidance of\ndouble taxation, i.e., the Central Government may enter into an\nagreement with the Government of any country ... nbenefit of double taxation relief by way of avoidance is granted to\nthe assessee in both the countries.\n38. Secondly, under section 90(1)(a)(i) of the Act, once such\nassessee has paid Income-tax, under the Act as well as the tax in\nthe other country, by such

M/S WIPRO LIMITED,BANGALORE vs. ASST.C.I.T., BANGALORE

Appeals is partly allowed for statistical\npurposes as in earlier orders of this Tribunal

ITA 222/BANG/2016[2011-12]Status: DisposedITAT Bangalore13 Jun 2024AY 2011-12

For Appellant: Sri Dhyan Chinnappa, Sr. A.R. and Sri Sandeep Huilgol, A.RFor Respondent: Ms. Neera Malhotra, D.R

Section 37(1)Section 90Section 91

this background, when we notice section 90 of the Act-relief\nfrom double taxation is granted in the following circumstances.\nFirstly, section 90(1)(b) of the Act speaks about avoidance of\ndouble taxation, i.e., the Central Government may enter into an\nagreement with the Government of any country ... this background, when we notice section 90 of the Act—\nrelief from double taxation is granted in the following\ncircumstances.\nFirstly, section 90(1)(b) of the Act speaks about avoidance of double\ntaxation, i.e., the Central Government may enter into an agreement with\nthe Government of any country

SMT. IRVIND KAUR GUJRAL,JAIPUR vs. ITO, WARD-1(3), JAIPUR, JAIPUR

In the result, appeal of the assessee is dismissed

ITA 477/JPR/2023[2018-19]Status: DisposedITAT Jaipur09 Nov 2023AY 2018-19

Bench: SHRI SANDEEP GOSAIN (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Sh. P. C. Parwal (CA)For Respondent: Smt. Monisha Choudhary (Addl.CIT)

Section 143(3)Section 5(1)(c)Section 90(3)

91/2008 dated 28.08.2008 and construed the words “may be taxed” as “shall be taxed” 8. We have gone through the provisions of Section 90(1) and Section 90(3), and the notification of the CBDT and impact of MLIs. ……… 9. Thus, we find that in the absence of an express ... taxed” cannot be construed to mean “shall be taxable only in the resident state” , unless it is expressly stated . Provisions of Section 90(1)(a)(i) is clearly applicable to the facts of the case . 10. In the result, both the appeals of the assessee are allowed.” In the above