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Section 40(a)(i) Disallowance Deleted Applying DTAA Non-Discrimination Clause: ITAT Delhi
Case Law Details
- Case Name
- Honda Cars India Ltd. Vs DCIT (LTU) (ITAT Delhi)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2009-10
- Courts
- All ITAT, ITAT Delhi
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Honda Cars India Ltd. Vs DCIT (LTU) (ITAT Delhi)
These were cross appeals against the order of the CIT(A)-LTU, New Delhi dated 31 March 2014 for Assessment Year 2009-10. The assessee, Honda Cars India Ltd. (formerly Honda Siel Cars India Ltd.), engaged in the manufacture and sale of cars, filed its return declaring nil income. The Assessing Officer completed the assessment under Sections 143(3) read with 144C, determining total income at ₹1,665.09 crore after, inter alia, disallowing payments under Section 40(a)(i), treating royalty and lump sum fees as capital expenditure, ...
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