DCIT, CIRCLE-8(1), KOLKATA, KOLKATA vs. ITC LIMITED, KOLKATA

In the result appeals of the assessee are partly allowed for statistical purposes and the appeals of the revenue are dismissed

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarma]

40a(i) could be made. We note that the assessee has made remittances to 8 foreign parties which need to be examined at the level of the AO in the light of DTAAs and ascertain whether the assessee is covered under the Treaties. Needless to mention that if the AO can also find out about the examination

ITC LIMITED,KOLKATA vs. ACIT, RANGE-8, KOLKATA, KOLKATA

In the result appeals of the assessee are partly allowed for statistical purposes and the appeals of the revenue are dismissed