GUALA CLOSURES (INDIA) PVT. LTD.,PANAJI vs. THE INCOME TAX OFFICER, WARD-1(1), PANAJI., PANAJI
In the result, the appeal filed by the assessee is partly allowed for statistical purpose
ITA 62/PAN/2017[2012-13]Status: DisposedITAT Panaji29 Jul 2025AY 2012-13
Bench: Shri Pavan Kumar Gadale & Shri G D Padmahshalii T A.No.62/Pan/2017 (A.Y.2012-13 ) Guala Closures(India) Vs. I T O Ward1(1), Private Limited, Aaykar Bhavan, D-1, Seasa Ghor, Edc, Patto, 20,Edc Complex, Panjim-403001. Patto, Goa. Panaji-403001, Goa Pan/Gir No.:Aaacg4447J Appellant .. Respondent
For Appellant: Shri.Nirajsheth. ARFor Respondent: Shri.Satish M .CIT DR
Section 115Section 143(3)Section 144C(5)
10% under the India-Netherlands tax treaty read with protocol treaty and the excess DDT paid should be refunded along with the interest. We find this disputed issue was decided by the Special Bench (Mumbai) in ITA. No 6997/Mum/2019 in the revenue appeal of DCIT Vs Total oil India Pvt Ltd & others vide order dated 20-4-2023.We considered it appropriate
