← All Phrases

“Section 90(2)”

Section References (mined)Section 90Section 90(2)547 judgments

The decision most relied on for Section 90(2) is Union of India v. Azadi Bachao Andolan (263 ITR 706), cited in 691 judgments on BharatTax.

Leading authorities on Section 90(2)

Union of India v. Azadi Bachao Andolan
263 ITR 706 · 2003 · Supreme Court
691
citing judgments

A citizen is free to carry on business within the law, and mere tax planning without a motive to evade taxes through colorable devices is not frowned upon. The liability to taxation, for the purpose of tax treaty application, is a legal situation, not the fiscal fact of actual payment.

CIT v. De Beers India Minerals (P.) Ltd.
346 ITR 467 · 2012 · High Court
371
citing judgments

For fees for technical or consultancy services to 'make available' technical knowledge or know-how under a DTAA, the service must transmit such knowledge, allowing the recipient to derive an enduring benefit and utilize it independently in the future.

Asia Satellite Telecommunications Co. Ltd. v. DIT
332 ITR 340 · 2011 · High Court
359
citing judgments

Payments for the use of equipment, such as satellite transponders, do not constitute 'royalty' under Section 9(1)(vi) of the Income-tax Act, 1961, or under applicable tax treaties, especially when there is no transfer of the right to use a process or underlying technology.

DIT v. New Skies Satellite BV
382 ITR 114 · 2016 · High Court
325
citing judgments

An amendment to the Income Tax Act, such as the Finance Act, 2012 amendment to Section 9(1)(vi) defining royalty, does not automatically override or alter the definition of 'royalty' as provided in a Double Taxation Avoidance Agreement (DTAA) unless the DTAA itself is bilaterally amended. The definition of royalty in a DTAA remains unaffected by unilateral changes to domestic law.

CIT v. Siemens Aktiongesellschaft
310 ITR 320 · 2009 · High Court
259
citing judgments

Reimbursements of actual expenses without any profit element are not taxable income. Additionally, mere amendments to the Income-tax Act do not override the provisions of Double Taxation Avoidance Agreements (DTAAs).

Skycell Communications Ltd. v. DCIT
251 ITR 53 · 2001 · High Court
253
citing judgments

Technical services involve human intervention and expertise, not just routine or machine-based operations. Routine customer support and standard facility provision through technology do not constitute technical services under the Act.

Shivsagar Veg Restaurant v. ACIT
317 ITR 433 · 2009 · High Court
202
citing judgments

Orders that are inordinately delayed are liable to be recalled and heard afresh, and the Appellate Tribunal President should frame guidelines for timely disposal of appeals.

153 (Gujarat) 8 Shakti Karnawat v. ITO
296 ITR 90 · 2008 · High Court
171
citing judgments

A live link of third-party information can form the basis for reopening an assessment under Section 148, provided it contains material facts necessary for assessment. The Assessing Officer must demonstrate a "reason to believe" that income has escaped assessment, which can be satisfied by such information even if it pertains to other assessees or relates to accommodation entries.

Judgments citing Section 90(2)

Owens Corning (Singapore) Pte Ltd, Mumbai vs. Deputy Commissioner of Income Tax (International Tax ) Circle -3(2)(2), Mumbai

In the result, the appeal by the assessee is allowed

ITA 1238/MUM/2025[2022-23]Status: DisposedITAT Mumbai14 May 2025AY 2022-23

Bench: Shri Narendra Kumar Billaiyashri Sandeep Singh Karhailowens Corning (Singapore) Pte Ltd., C/O Owens Corning (India) Pvt. Ltd., 7Th Floor, Alpha Building, Hiranandani Gardens, Powai ............... Appellant Maharashtra - 400076 Pan : Aabco5666L V/S Dcit (It) – 3(2)(2) 6Th Floor, Kautilya Bhawan, ……………… Respondent Bandra Kurla Complex, Mumbai - 400051

For Appellant: Shri Sandeep BhallaFor Respondent: Shri Soumendu Kumar Dash, Sr.DR
Section 115ASection 142(1)Section 143(2)Section 143(3)Section 144C(13)Section 234BSection 9Section 9(1)(vii)Section 90(2)

Appellant submits that considering the facts and circumstances of the case and the law prevailing on the subject, as per section 90(2) of the Act, the income from fees for technical services ought to have been taxed at the beneficial tax rate of 10% under Article 12 of India

Swapan Bhttacharya, Kolkata vs. ACIT, Circle 61, Kolkata

In the result, the appeal filed by the assessee is partly allowed for statistical purposes

ITA 242/KOL/2025[2017-18]Status: DisposedITAT Kolkata05 May 2025AY 2017-18

Bench: Shri George Mathan & Shri Rakesh Mishra

Section 139(1)Section 143(2)Section 143(3)Section 250Section 90

assessee: 165. The conclusions in the aforestated paragraph have no direct relevance to the facts at hand as the effect of section 90(2) of the Income-tax Act, read with explanation 4 thereof, is to treat the DTAA provisions as the law that must be followed by Indian courts

M/S. Philips Electronics Nederland B.V., Kolkata vs. A.C.I.T.(International Taxation), Circle - 2(1), Kolkata

In the result, appeal of the assessee is allowed

ITA 134/KOL/2023[2020-2021]Status: DisposedITAT Kolkata30 Apr 2025AY 2020-2021

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarmaआयकर अपील सं/Ita No.134/Kol/2023 (नििाारण वर्ा / Assessment Year : 2020-2021) M/S Philips Electronics Vs Acit(International Taxation), Nederland B.V. Circle-2(1), Kolkata C/O Deloitte Haskins & Sells Llp Bengal Intelligent Park, Building Omega, 13Th& 14Th Floor, Block- Ep & Gp, Sector-V, Salt Lake Electronic Complex, Kolkata- 700091 Pan No. :Aafcp4361F (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) नििााररतीकीओरसे /Assessee By : Shri Ketan Ved, Ar राजस्वकीओरसे /Revenue By : Shri Guru Bhashyam, Cit-Dr सुनवाई की तारीख / Date Of Hearing : 06/02/2025 घोषणा की तारीख/Date Of Pronouncement : 30/04/2025 आदेश / O R D E R Per Rajesh Kumar, Am: This Is An Appeal Filed By The Assessee Against The Order Dated 31.12.2022, Passed By The Acit, Circle-2(1), It, Kolkata Giving Effect To The Direction Given By The Dispute Resolution Panel-2, New Delhi(In Short The ‘Drp’), Dated 04.11.2022, Thereby Finalizing The Assessment Order In Accordance With The Provisions Of Section 144C(13) R.W.S. 143(3) Of The Act. 2. At The Outset, Ld. Ar Drew Our Attention To The Additional Ground Filed By The Assessee & Submitted That The Appeal Of The Assessee May Be Decided On The Following Additional Grounds Taken By The Assessee :-

For Appellant: Shri Ketan Ved, ARFor Respondent: Shri Guru Bhashyam, CIT-DR
Section 142(1)Section 143(2)Section 143(3)Section 144CSection 144C(13)Section 156Section 90(2)

that in the Act being more beneficial of the two to the Assessee. Accordingly the Assessing Officer in accordance with section 90(2) of the Act, calculated taxable income at the rate mentioned under Article 12(4) & (5) of the DTAA in the tabulated form in para 3.12 at page

Aban Offshore Limited, Chennai vs. DCIT, Intl, Tax 1(1), Chennai

ITA 1240/CHNY/2024[2014-15]Status: DisposedITAT Chennai28 Apr 2025AY 2014-15

Bench: Shri Aby T.Varkey, Hon'Ble & Shri S.R. Raghunatha, Hon'Bleआयकर अपीलसं./Ita Nos.: 1240/Chny/2024 निर्धारण वर्ष / Assessment Year: 2014-15 Aban Offshore Limited, 113, Janpriya Crest, Pantheon Road, Egmore, Chennai - 600 008. Pan: Aaaca 3012H (अपीलार्थी/Appellant) अपीलार्थी की ओर से/Appellant By प्रत्यर्थी की ओर से/Respondent By The Deputy Commissioner Of Income Tax, Vs. International Taxation 1(1), Chennai. (प्रत्यर्थी/Respondent) : Shri P. Murali Mohan Rao, Ca (Through Virtual Mode) : Ms. R. Anita, Addl.Cit सुनवाई की तारीख/Date Of Hearing : 19.02.2025 घोषणा की तारीख/Date Of Pronouncement : 28.04.2025 आदेश /O R Der Per S. R. Raghunatha: This Appeal By The Assessee Is Filed Against The Order Of The Commissioner Of Income Tax (Appeals), Chennai-16, Dated 13.03.2024 For The Assessment Year 2014-15. 2. The Assessee Has Raised The Following Grounds Of Appeal: 1. The Ld. Cit(A) Erred In Not Considering The Fact That The Order Passed U/S.250 Of The Income Tax Act, 1961, Dated 13.03.2024 Is Erroneous Both On Facts & In Law To The Extent The Order Is Prejudicial To The Interest Of The Appellant :-2-:

Section 115ASection 195(2)Section 250Section 44BSection 9(1)Section 9(1)(vi)Section 90

आयकर अपीलीय अधिकरण, 'सी' न्यायपीठ, चेन्नई IN THE INCOME TAX APPELLATE TRIBUNAL 'C' BENCH, CHENNAI श्री एबी टी. वर्की, न्यायिक

M/S Union Bank of India, Mumbai vs. Deputy Commissioner of Incomet Tax. Circle- Ltu -2, Mumbai

In the result appeal of the assessee bearing ITA No

ITA 1678/MUM/2024[2015-16]Status: DisposedITAT Mumbai23 Apr 2025AY 2015-16

Bench: BEFOR SHRI ANIKESH BANERJEE (Judicial Member)

For Appellant: Shri C NareshFor Respondent: ShriKrishna Kumar SR. DR
Section 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 250Section 90

relied upon by assessee and added the amount of Rs. 65.03 crore to taxable income. The Ld. AO while relying on provisions of section 90(2) and 90(4) failed to note that while 90(2) also provides for avoidance of double taxation 90

Assistant Commissioner of Income Tax Ltu Circle 1 Chennai, Chennai vs. E I D Parry India Limited, Chennai

In the result, all the appeals filed by the assessee are partly allowed for statistical purposes and the appeal filed by the Revenue is dismissed

ITA 3251/CHNY/2024[2012-13]Status: DisposedITAT Chennai21 Apr 2025AY 2012-13

Bench: Shri George George Kand Shri S.R. Raghunathait(Tp)A. Nos.:105, 106, 107/Chny/2024 & Ita No.3113/Chny/2024 िनधा"रण वष"/Assessment Years: 2011-12, 2012-13, 2013-14 & 2014-15 M/S. E.I.D. Parry India Ltd., The Deputy Commissioner Of No. 234, Dare House, Nsc Vs. Income Tax, Bose Road, Parrys Corner, Large Taxpayer Unit -1, Chennai 600 001. Chennai. [Pan: Aaace-0702-C] (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Shri R. Vijayaraghavan, AdvocateFor Respondent: Shri A. Sasikumar, CIT
Section 143(1)Section 143(2)Section 250Section 92BSection 92C

assessee in the context of the relevant DTAAs and the definition of FTS therein and to grant relief as per the provisions of section 90(2) of the Act. The ld. AR, during the course of hearing, submitted that the assessee does not have any grievance on this issue from

M/S. Eid Parry India Ltd., Chennai vs. DCIT, Ltu-1, Chennai

In the result, all the appeals filed by the assessee are partly allowed for statistical purposes and the appeal filed by the Revenue is dismissed

ITA 3113/CHNY/2024[2014-15]Status: DisposedITAT Chennai21 Apr 2025AY 2014-15

Bench: Shri George George Kand Shri S.R. Raghunathait(Tp)A. Nos.:105, 106, 107/Chny/2024 & Ita No.3113/Chny/2024 िनधा"रण वष"/Assessment Years: 2011-12, 2012-13, 2013-14 & 2014-15 M/S. E.I.D. Parry India Ltd., The Deputy Commissioner Of No. 234, Dare House, Nsc Vs. Income Tax, Bose Road, Parrys Corner, Large Taxpayer Unit -1, Chennai 600 001. Chennai. [Pan: Aaace-0702-C] (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Shri R. Vijayaraghavan, AdvocateFor Respondent: Shri A. Sasikumar, CIT
Section 143(1)Section 143(2)Section 250Section 92BSection 92C

assessee in the context of the relevant DTAAs and the definition of FTS therein and to grant relief as per the provisions of section 90(2) of the Act. The ld. AR, during the course of hearing, submitted that the assessee does not have any grievance on this issue from

Indira Veluri, Bangalore vs. Income Tax Officer, Ward-4(2)(3), Bangalore

In the result, the appeal is allowed

ITA 2513/BANG/2024[2021-2022]Status: DisposedITAT Bangalore21 Apr 2025AY 2021-2022

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2021-22

For Appellant: Sri Pavan Kumar, A.RFor Respondent: Sri Ganesh R Gale, Standing counsel for department
Section 250Section 253(5)

Delhi) • CIT vs ACE Multitaxes Systems (P.) Ltd [2009] 317 ITR 207 (Karnataka). 13. It was submitted that as per the provisions of section 90(2) of the Act, where the Central Government of India has entered into a DTAA, the provisions of the Act would apply to the extent

Shell International Petroleum Company Limited, Mumbai vs. Deputy Commissioner of Income Tax (Int Taxation)_4(2)(1), Mumbai

Accordingly we hold that the treatment of IT services is not in the nature of FTS and cannot be taxed in India. Ground No.25 to 27 are allowed and Ground No

ITA 3317/MUM/2023[2020-21]Status: DisposedITAT Mumbai21 Apr 2025AY 2020-21

Bench: Ms Padmavathy S, Am & Shri Raj Kumar Chauhan, Jm

For Respondent: Shri Vivek Perampurna, CIT-DR
Section 143(3)

thus the provisions as per DTAA which is more beneficial to the assessee should only be applied in assessee's case as per section 90(2) of the Act. In this regard it is relevant to consider the following observations of the Hon'ble Supreme Court in the case ... wider and less beneficial to the assessee than the definition contained in the M/s Shell International Petroleum Co. Ltd. DTAA, as per section 90(2) of the Income-tax Act read with explanation 4 thereof, and Article 3(2) of the DTAA. Further, the expression "copyright" has to be understood

Shell International Petroleum Company Limitedium, Mumbai vs. Dy Commissioner of Income Tax (International Taxation)-4(2)(1), Mumbai

Accordingly we hold that the treatment of IT services is not in the nature of FTS and cannot be taxed in India. Ground No.25 to 27 are allowed and Ground No

ITA 995/MUM/2022[2018-19]Status: DisposedITAT Mumbai21 Apr 2025AY 2018-19

Bench: Ms Padmavathy S, Am & Shri Raj Kumar Chauhan, Jm

For Respondent: Shri Vivek Perampurna, CIT-DR
Section 143(3)

thus the provisions as per DTAA which is more beneficial to the assessee should only be applied in assessee's case as per section 90(2) of the Act. In this regard it is relevant to consider the following observations of the Hon'ble Supreme Court in the case ... wider and less beneficial to the assessee than the definition contained in the M/s Shell International Petroleum Co. Ltd. DTAA, as per section 90(2) of the Income-tax Act read with explanation 4 thereof, and Article 3(2) of the DTAA. Further, the expression "copyright" has to be understood

Shell International Petroleum Company Ltd., Mumbai vs. DCIT (It) 4(2)(1), Mumbai

Accordingly we hold that the treatment of IT services is not in the nature of FTS and cannot be taxed in India. Ground No.25 to 27 are allowed and Ground No

ITA 2307/MUM/2022[2019-20]Status: DisposedITAT Mumbai21 Apr 2025AY 2019-20

Bench: Ms Padmavathy S, Am & Shri Raj Kumar Chauhan, Jm

For Respondent: Shri Vivek Perampurna, CIT-DR
Section 143(3)

thus the provisions as per DTAA which is more beneficial to the assessee should only be applied in assessee's case as per section 90(2) of the Act. In this regard it is relevant to consider the following observations of the Hon'ble Supreme Court in the case ... wider and less beneficial to the assessee than the definition contained in the M/s Shell International Petroleum Co. Ltd. DTAA, as per section 90(2) of the Income-tax Act read with explanation 4 thereof, and Article 3(2) of the DTAA. Further, the expression "copyright" has to be understood

M/S. Shell Interational Petroleum Co. Ltd., Mumbai vs. Dy CIT (International Taxation)-4(2)(1), Mumbai

ITA 1244/MUM/2021[2017-18]Status: DisposedITAT Mumbai21 Apr 2025AY 2017-18

Bench: Ms Padmavathy S, Am & Shri Raj Kumar Chauhan, Jm

Section 143(3)Section 234ASection 271(1)(c)

thus the provisions as per DTAA which is more beneficial to the assessee should only be applied in assessee's case as per section 90(2) of the Act. In this regard it is relevant to consider the following observations of the Hon'ble Supreme Court in the case ... have to be ignored if it is wider and less beneficial to the assessee than the definition contained in the DTAA, as per section 90(2) of the Income-tax Act read with explanation 4 thereof, and Article 3(2) of the DTAA. Further, the expression "copyright

M/S Shell International Petroleum Company Ltd., Mumbai vs. Dy CIT (It)- 4 (2)(1), Mumbai

ITA 7499/MUM/2019[2016-17]Status: DisposedITAT Mumbai21 Apr 2025AY 2016-17

Bench: Ms Padmavathy S, Am & Shri Raj Kumar Chauhan, Jm

For Appellant: Respondent)For Respondent: Shri Vivek Perampurna, CIT-DR
Section 143(3)Section 271(1)(c)

thus the provisions as per DTAA which is more beneficial to the assessee should only be applied in assessee's case as per section 90(2) of the Act. In this regard it is relevant to consider the following observations of the Hon'ble Supreme Court in the case ... have to be ignored if it is wider and less beneficial to the assessee than the definition contained in the DTAA, as per section 90(2) of the Income-tax Act read with explanation 4 thereof, and Article 3(2) of the DTAA. Further, the expression "copyright

Aditya Somani, Hooghly vs. Income Tax Officer, Ward 34(1), Kolkata

In the result, the appeal filed by the assessee is allowed

ITA 1897/KOL/2024[2021-22]Status: DisposedITAT Kolkata16 Apr 2025AY 2021-22

Bench: Shri Rajesh Kumar&Shri Pradip Kumar Choubey]

Section 1Section 139Section 143(1)Section 154Section 234BSection 6Section 90

tune of Rs. 17,72,470/- was deducted in United Kingdom under DTAA between India and UK and provision of Section 90(2) of the Act. We also note that Rule 128 sub-Rule 9 provides that Form- 67 should be filed on or before the due date of filing

Bay Capital India Fund Limited, Mumbai vs. CIT (A) 55, Mumbai

In the result, the appeal by the assessee is allowed

ITA 6355/MUM/2024[2019-20]Status: DisposedITAT Mumbai08 Apr 2025AY 2019-20

Bench: Shri B.R. Baskaranshri Sandeep Singh Karhail

For Appellant: Shri Sukhsagar Syal, AdvFor Respondent: Ms. Monika H. Pande, Sr. DR
Section 143(1)Section 195Section 250Section 70Section 70(2)Section 70(3)

India- Mauritius DTAA, the Revenue has restricted the benefit granted to the assessee under Article 13(4) of the India-Mauritius DTAA r.w. Section 90(2) of the Act. Thus, as per the assessee, the entire amount of long-term capital gains, i.e., Rs.38,58,55,851/-, from the sale ... based on the principle to provide tax relief by preventing double taxation. 6. 4. 3. As per India Mauritius DTAA read with section 90(2), capital gains are to be taxed based on the place of residence of the recipient, by granting relief of tax on such gains in India

Income Tax Officer, International Taxation, Ward-1(2), Benglauru, Bengaluru vs. Unitedlex India Pvt. Ltd. (Earlier Known As I-Runway India Private Limited), Bengaluru

In the result, appeal of the revenue is dismissed

ITA 1243/BANG/2024[2015-16]Status: DisposedITAT Bangalore07 Apr 2025AY 2015-16

Bench: Shri Laxmi Prasad Sahu & Shri Keshav Dubeyassessment Year :2015-16

For Appellant: Smt. Manasa Ananthan, A.RFor Respondent: Ms. Neha Sahay, D.R
Section 143(3)Section 195Section 201Section 201(1)Section 250Section 40Section 9(1)(vii)

section 206AA of the Act, which begins with non-obstante clause therefore it over-rights the other sections of the Act including section 90(2) of the Act and accordingly a higher rate of tax for FTS @25% as per section 115A of the Act was applied being the higher

Bhupendra Bora, Ghaziabad vs. DCIT, Dehradun

In the result, the appeal is allowed

ITA 230/DDN/2024[2019-20]Status: DisposedITAT Dehradun02 Apr 2025AY 2019-20

Bench: Shri M. Balaganesh & Shri Satbeer Singh Godara(Through Video Conferencing) Bhupendra Bora, Vs. Dcit, Flat No. S4, Plot No. 618A, Circle-1(1)(1), Sector-1, Vaishali, Dehradun Ghaziabad (Appellant) (Respondent) Pan: Ajkpb5486A Assessee By : None Revenue By: Shri A. S. Rana, Sr. Dr Date Of Hearing 17/03/2025 Date Of Pronouncement 02/04/2025

For Appellant: NoneFor Respondent: Shri A. S. Rana, Sr. DR
Section 139(1)Section 139(4)Section 143(1)Section 192Section 90

Delhi) ♦ CIT v. ACE Multitaxes Systems (P.) Ltd. [2009] 317 ITR 207 (Kar.) 13. It was submitted that as per the provisions of section 90(2) of the Act, where the Central Government of India has entered into a DTAA, the provisions of the Act would apply to the extent

Qualcomm Asia Pacific Pte Ltd, Singapore vs. Deputy Commissioner of Income-Tax, International Tax -Circle 3(3)(1), Mumbai

The appeal of the assessee is allowed

ITA 686/MUM/2025[2020-21]Status: DisposedITAT Mumbai28 Mar 2025AY 2020-21

Bench: Shri Amit Shukla, Jm & Ms Padmavathy S, Am

For Appellant: Shri Nishant Thakkar / Ms Jasmin
Section 143(1)Section 143(1)(a)Section 154Section 251

treaty provisions are beneficial as compared to the provisions of the Act; the taxpayer has right to rely on the treaty provisions. 20. Section 90(2) of the Act reads as under: "90(2) Where the Central Government has entered into an agreement with the Government of any country outside ... taxpayer chooses not to claim treaty benefit as we have already noted above that he can do so under the provisions of section 90(2) of the Act. When he does so, his income will have to be computed under the provisions of the Act for that year. This will

Sridharan Venkatanarayanan, Secunderabad vs. DCIT., Circle- 12(1), Hyderabad

In the result, the appeal of the assessee is allowed

ITA 32/HYD/2025[2018-19]Status: DisposedITAT Hyderabad27 Mar 2025AY 2018-19

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha, G.आ.अपी.सं /Ita No.32/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2018-19) Sri Sridharan Vs. Dy. Commissioner Of Venkatanarayanan Income Tax, Circle 12(1) Secunderabad Hyderabad Pan:Bgaps6316N (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: C.A V. Balaji राज" व "ारा/Revenue By:: Dr. Sachin Kumar, Dr सुनवाई की तारीख/Date Of Hearing: 24/03/2025 घोषणा की तारीख/Pronouncement: 27/03/2025 आदेश/Order

For Appellant: C.A V. BalajiFor Respondent: : Dr. Sachin Kumar, DR
Section 119(2)(b)Section 139(1)Section 139(5)Section 143(1)Section 91

taxable in India. Article 24 of India-Italy DTAA provides for credit towards foreign taxes paid for earning income arising from foreign soil. Section 90(2) of the Act provides that provisions of this Act shall apply to the extent they are more beneficial to the assessee. Article

Credit Agricole Corporate and Investment Bank, Mumbai vs. The Dy-CIT (Int. Taxation)-2(1)(1), Mumbai

Accordingly these grounds are dismissed as not pressed

ITA 749/MUM/2022[2017-18]Status: DisposedITAT Mumbai20 Mar 2025AY 2017-18

Bench: Smt Beena Pillai, Jm & Ms Padmavathy S, Am I.T. (Tp) A. No. 1479/Mum/2015 (Assessment Year: 2010-11) Credit Agricole Corporate & Dcit (International Taxation)- Investment Bank (Formerly 2(1)(1), 1St Floor, Room No. 136, Known As ‘Calyon Bank’) Vs. 11Th Floor, Hoechst House, Scindia House, N.M. Marg, Nariman Point, Mumbai-400021. Ballard Pier, Mumbai-400038. Pan: Aaccc3872B Appellant) : Respondent)

Section 143(3)

IN THE INCOME TAX APPELLATE TRIBUNAL “I” BENCH, MUMBAI BEFORE SMT BEENA PILLAI, JM & MS PADMAVATHY S, AM I.T. (TP