DCIT, CIRCLE- 2, INTL. TAXATION, DEHRADUN vs. SCHLUMBERGER ASIA SERVICES LTD., DEHRADUN
In the result, the appeal of the assessee for the Asst Year 2015-16 is partly allowed and that of the revenue is dismissed
ITA 6173/DEL/2017[2014-15]Status: DisposedITAT Dehradun15 Sept 2023AY 2014-15
Bench: Shri Saktijit Dey & Shri M. Balaganeshita No. 5223/Del/2018 (A. Y.: 2015-16) Schlumberger Asia Services Ltd, Vs. Dcit, 14Th Floor, Tower-C, Building Circle-2, No. 1, Dlf City, Phase-Ii, International Taxation, Gurgaon Dehradun (Appellant) (Respondent) Pan: Aadcs1107J
For Appellant: Shri P. J. Pardiwalla, Sr. AdvFor Respondent: Shri Mayank Kumar, JCIT, DR
Section 143(3)Section 44BSection 9(1)(vii)
15
per cent of the gross amount of such interest.
3. Notwithstanding the provisions of paragraph 2, interest arising in a Contracting State shall be exempt from tax in that State, if:—
(a) the payer of the interest is the Government of that Contracting
State or a local authority thereof, or (b) the interest is paid to any agency