KDDI CORPORATION,JAPAN vs. DEPUTY COMMISSIONER OF INCOME-TAX (INTERNATIONAL TAXATION), CIRCLE 2(1), BANGALORE, KARNATAKA, JAPAN
ITA 102/BANG/2024[2015-16]Status: DisposedITAT Bangalore15 Apr 2024AY 2015-16
Bench: Smt. Beena Pillai & Shri Laxmi Prasad Sahus.P. Nos. 7 To 9/Bang/2024 (In It(It)A Nos. 100 To 102/Bang/2024) & It(It)A Nos. 100 To 102/Bang/2024
For Appellant: Shri Arjit Prasad, Sr. AdvocateFor Respondent: Dr. Subash K R, CIT-DR
Section 143(3)Section 144C(1)Section 144C(3)Section 147Section 148Section 201
reassessment proceedings was initiated against the assessee for
the years under consideration and notice u/s. 148 of the act was
issued to the assessee.
2.6 Thereafter the Ld.AO passed an order dated 29.03.2023 u/s.
144C(1) of the act holding that IUC received by the assessee are
in the nature of 'Royalty' under the provisions of the act, as well
