Principal Commissioner of Income Tax-2 vs. M/s.Viskha Container Terminal Private Limited

Bench: RAMESH RANGANATHAN,KONGARA VIJAYA LAKSHMI

3) read with 92CA and 144C of the IT Act. The undisputed facts also reveal that the respondent company pursuant to the scheme of amalgamation stood merged with the Wipro Limited, the Scheme of amalgamation was approved by the High Court of Andhra Pradesh vide order dated 21.02.2008 and by the High Court of Karnataka vide order dated 10.01.2008 with

Sarwar Ahuja, vs. Income Tax Officer, Ward 6(1),

Accordingly dismissed. Pending applications are also dismissed

Bench: The Learned Itat Assailing The Order Dated 05.01.2024 Passed By The Assessing Officer [Ao] Under Section 147 Read With Section 144C(13) Of The Act. 3. The Assessee Is A Company, Which Is Tax Resident Of The United States Of America [Usa]. The Assessee Has Also Furnished A Tax Residency Certificate [Trc] From The Concerned Authorities Of The Said Country. Digitally Signed By:Tarun Rana Signing Date:01.06.2025 13:30:53 Signature Not Verified

transfer of technical plan or technical design within the meaning of Article 12(4) of Digitally Signed By:TARUN RANA Signing Date:01.06.2025 13:30:53 Signature Not Verified ITA 173/2025 Page 3 of 14 India-USA DTAA?” 5. As noted above, the Assessee is a tax resident of USA and is engaged in the business of providing services which