KREUZ CHALLENGER PTE LTD,SINGAPURE vs. ACIT, INTERNATIONAL TAXATION CIRCLE2(1)(2), NEW DELHI
The appeal of the assessee is allowed
ITA 2373/DEL/2022[2019-20]Status: DisposedITAT Delhi09 Dec 2024AY 2019-20
Bench: Shri M. Balaganesh & Shri Anubhav Sharmaassessment Year: 2019-20 Kreuz Challenger Pte Ltd., Vs Acit, 2, Venture Drive, International Taxation #24-01 Vision Exchange, Circle 2(1)(2), Singapore , 999999 New Delhi. Pan : Aahck3082A
For Appellant: Shri Salil Kapoor, AdvocateFor Respondent: Ms C. Chandra Kanta, CIT-DR
Section 115ASection 143(3)Section 144C(13)Section 197Section 44BSection 44DSection 9(1)(vi)Section 9(1)(vii)Section 90(2)
44D of the Act.”
11. However, no issue about taxability of receipt by a foreign resident, not having PE in India, from hire of vessel on time charter basis was examined in any form. So the reliance on the ONGC Case (supra) by the ld. Tax authorities was not justified.
12. This issue has been examined by the Mumbai Bench
