VAIJANTHI MAHAVIR OZA,MUMBAI vs. INCOME TAX OFFICER(IT)-3(3)(1), MUMBAI
In the result, appeal of the assessee in ITA no
ITA 5799/MUM/2017[2014-15]Status: DisposedITAT Mumbai03 Apr 2019AY 2014-15
Bench: Shri Saktijit Dey & Shri Ramit Kocharआयकर अपीऱ सं./I.T.A. No.5799/Mum/2017 (नििाारण वर्ा / Assessment Year: 2014-15) बिाम/ Vaijanthi Mahavir Oza, Income Tax Officer- C/O. Chhajed & Doshi, (International Taxation)- 101, Hubtown Solaris, 3(3)(1) V. N.S Phadke Marg, Room No. 1628, Near East West Flyover, 16Th Floor Andheri (E), Air India Building Mumbai- 400069 Mumbai स्थायी ऱेखा सं./ Pan: Abepo5631J (अपीऱाथी /Appellant) (प्रत्यथी / Respondent) .. Assessee By: Shri. Piyush Chhajjed Revenue By: Miss. Deepika Arora (Dr) सुनवाई की तारीख /Date Of Hearing : 09.01.2019 घोषणा की तारीख /Date Of Pronouncement : 03.04.2019 आदेश / O R D E R Per Ramit Kochar: This Appeal, Filed By Assessee, Being Ita No. 5799/Mum/2017, Is Directed Against Appellate Order Dated 23.06.2017, Passed By Learned Commissioner Of Income Tax (Appeals)-57, Mumbai (Hereinafter Called “The Cit(A)”), For Assessment Year 2014-15, The Appellate Proceedings Had Arisen Before Learned Cit(A) From The Assessment Order Dated 23.12.2016 Passed By Learned Assessing Officer (Hereinafter Called “The Ao”) U/S 143(3) Of The Income-Tax Act, 1961 (Hereinafter Called “The Act”) For Ay 2014-15. I.T.A. No.5799/Mum/2017
For Appellant: Shri. Piyush ChhajjedFor Respondent: Miss. Deepika Arora (DR)
Section 1Section 143(3)Section 54Section 54F
4, section 5(2) and section 14, in case of non-residents, clearly requires that section 45 along with section 54 are also to be read conjointly with the provisions of section 5(2) of the Act in 10
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case of non-residents. To put it differently, the words 'in India' are automatically read into section
