NAT WEST MARKETS PLC- INDIA BRANCH ,KOLKATA vs. ACIT(I.T)-1(2), KOLKATA. , KOLKATA
In the result, the appeal of the assessee is allowed
ITA 1364/KOL/2023[2021-22]Status: DisposedITAT Kolkata31 Jan 2024AY 2021-22
Bench: Shri Rajesh Kumar, Am & Shri Sonjoy Sarma, Jm Nat West Markets Plc-India Acit (I.T)-1(2), Kolkata Branch Aaykar Bhavan Poorva, 2 Nd 907, Regus, 9Thfloor, Floor, Psarcadia,4A, Abandindra Nath Vs. 110, Shanti Pally, Thakur Sarani, Kolkata-700016, Kolkata-700107, West Bengal West Bengal (Appellant) (Respondent) Pan No. Aacct8020E Assessee By : Shri Percy Pardiwala, Ar Revenue By : Shri Gaurav Kanujia, Dr Date Of Hearing: 15.01.2025 Date Of Pronouncement : 31.01.2025
For Appellant: Shri Percy Pardiwala, ARFor Respondent: Shri Gaurav Kanujia, DR
Section 143(3)Section 144C(13)Section 44ASection 56Section 68
section 244A of the Act accrued to the assessee as the refund and interest was determined in the case of Netherlands Entity and not to the assessee. The ld. AR submitted that the assessee had taken over all assets and liabilities of the Indian branches that were in existence on 27.02.2017 and any amount which accrued thereafter to the Netherlands