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Assessee to whom DTAA applies, the provisions of Income Act shall applied to the extent they are more beneficial to the assessee
Case Law Details
- Case Name
- M/s Intelsat Corporation Vs. Assistant Director of Income Tax (ITAT Delhi)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2008- 09
- Courts
- All ITAT, ITAT Delhi
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Intelsat Corporation Vs. ADIT (International Taxation)– We have considered the facts of the case and submissions made before us. We have already mentioned that there is a distinguishable feature namely that the assessee has received payments from persons residents in India. However, the receipts have been taxed u/s 9(1)(vii), Explanation 2, Clause (vi) there under. The decision in the case of Asia Satellite Telecommunications Company Limited is to the contrary and in favor of the assessee. It is also a matter of fact on record that the assessee is a tax resident of USA and, therefore, th...
