MUFG BANK LTD,NEW DELHI vs. ACIT (INTERNATIONAL TAXATION) CIRCLE-2(2)(1), NEW DELHI
In the result appeal of the assessee is partly allowed
ITA 7895/DEL/2019[2015-16]Status: DisposedITAT Delhi16 Oct 2020AY 2015-16
Bench: Shri Amit Shukla & Shri Prashant Maharishi(Through Video Conferencing) Mufg Bank Ltd, Vs. Acit (International Taxation), 5Th Floor, Worldmark 2, Asset 8, Circle-2(2)(1), Aerocity, Nh-8, New Delhi New Delhi Pan: Aabct3880D (Appellant) (Respondent)
For Appellant: Shri Nishant Thakkar, AdvFor Respondent: Shr Surender Pal, CIT DR
Section 143(3)Section 14ASection 244ASection 37(1)Section 44C
permanent establishment of the assessee. He submitted that Section 44C of the act applies only when the income of the assessee is included under the provisions of Section 28 to Section 43A of the act. Therefore he submitted that assessee is not entitled to claim of deduction of 5% on the interest income on ECB loans.
24. We have carefully
