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Mere NMS-triggered email alert without basis cannot justify reassessment: ITAT Delhi
Case Law Details
- Case Name
- Kisan International Trading FZE Vs ACIT (ITAT Delhi)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2012-13
- Courts
- All ITAT, ITAT Delhi
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Kisan International Trading FZE Vs ACIT (ITAT Delhi)
Reopening Quashed—UAE Company Not Required to File ROI u/s 115A(5); AO Taxed Exactly Double the Real Interest Income; No Reasons, No Service of 148, No Disposal of Objections
Kisan International Trading FZE, a UAE tax-resident foreign company, received interest income of USD 7,48,401.66 (₹4,24,75,001) from IFFCO. TDS of ₹53,09,375 was correctly deducted @12.5% as per Article 11, India–UAE DTAA & section 195. Consequently, section 115A(5) exempted the Assessee from filing any return in India.
Despite this, AO trig...
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