SMT. IRVIND KAUR GUJRAL,JAIPUR vs. ITO, WARD-1(3), JAIPUR, JAIPUR
In the result, appeal of the assessee is dismissed
ITA 477/JPR/2023[2018-19]Status: DisposedITAT Jaipur09 Nov 2023AY 2018-19
Bench: SHRI SANDEEP GOSAIN (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)
For Appellant: Sh. P. C. Parwal (CA)For Respondent: Smt. Monisha Choudhary (Addl.CIT)
Section 143(3)Section 5(1)(c)Section 90(3)
permanent establishment.
Article 8- Ships and Aircraft (PB 20)
1. Profits from the operation of ships or aircraft, including interest on funds connected with that operation, derived by a resident of one of the Contracting
States shall be taxable only in that State.
2. Notwithstanding the provisions of paragraph (1), such profits may be taxed in the other Contracting State