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