GUALA CLOSURES (INDIA) PVT. LTD.,PANAJI vs. THE INCOME TAX OFFICER, WARD - 1(1), PANAJI
In the result, the appeal filed by the assessee is partly allowed for statistical purpose
ITA 344/PAN/2017[2013-14]Status: DisposedITAT Panaji02 Apr 2026AY 2013-14
Bench: Shri Pavan Kumar Gadale & Shri G D Padmahshalii T A.No.344/Pan/2017 (A.Y.2013-14 ) Guala Closures(India) Vs. I T O Ward1(1), Private Limited, Aaykar Bhavan, D-1, Sesa Ghor, Edc, Patto, 20,Edc Complex, Panjim-403001. Patto, Goa. Panaji-403001, Goa Pan/Gir No.:Aaacg4447J Appellant .. Respondent
For Appellant: Shri.Niraj Sheth. ARFor Respondent: Shri.Renga Ranjan.CIT DR
Section 115Section 143(3)Section 144C(5)Section 2(43)Section 4Section 90
3) which is paid by the Company, resident of India to a resident of UK and therefore, in our view, Article 11(1) is automatically triggered, consequently triggering the restriction in rate of tax under Article 11(2).
60. Thus, the BFAR erred in not appreciating that the tax under Section 115- O is an additional tax under
