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2 results for “capital gains”+ Section 45Aclear

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Key Topics

Section 26323Section 143(3)4Double Taxation/DTAA2Revision u/s 2632

SAPIEN FUNDS LTD,MAURITIUS vs. CIT(INTERNATIONAL TAXATION), NEW DELHI

In the result, appeal of the assessee is allowed

ITA 2890/DEL/2022[2018-19]Status: DisposedITAT Delhi21 Nov 2023AY 2018-19

Bench: Shri Challa Nagendra Prasada N D Shri M. Balaganesh

For Appellant: Advocate
Section 143(3)Section 263

capital gains on derivative transactions were not taxed under the Income Tax Act rejecting the contention of the assessee that the assessee is entitled for the benefit of Article 11 of the Indo Mauritius DTAA as the assessee is tax resident of Mauritius. The ld. 4 I.T.A. No. 2890/Del/2022 Counsel submits that for the assessment year 2017-18 the order

SAPEIN FUNDS LTD.,MAURITIUS vs. CIT (INTERNATIONAL TAXATION) DELHI-3, NEW DELHI

In the result, the appeal of the assessee is allowed

ITA 976/DEL/2022[2017-18]Status: Disposed
ITAT Delhi
08 Jun 2023
AY 2017-18

Bench: Sh. Saktijit Deydr. B. R. R. Kumar

For Appellant: Sh. Salil Kapoor, Adv. &For Respondent: Sh. Vizay Vasanta, CIT-DR
Section 143(3)Section 263

Capital Markets Ltd. 7. The Assessee is a tax resident of Mauritius and had shown income of Rs.12,93,77,569/- as exempt income for A.Y. 2017- 18. The case was selected under CASS. The reasons cited for scrutiny were: 6 Sapein Funds Ltd. 1. Foreign Remittances made to person(s) located in low tax jurisdiction countries (Assessee being remitter