Income received includes tax deducted in Korea on income of Indian branch of Japanese bank

IN THE ITAT MUMBAI BENCH ‘L’ Deputy Director of Income-tax (IT) Versus Sumitomo Mitsui Banking Corpn. IT Appeal No. 6496 (Mum.) of 2006 [Assessment year 2001-02] December 5, 2012 ORDER B. Ramakotaiah, Accountant Member This is a Revenue appeal against the orders of the CIT (A)-6 Mumbai dated 9.10.2006. The issue in the appeal is with reference to the deletion of penalty under section 271(1)(c) of the I.T. Act levied by the DDIT (International Taxation) on the following three issues: (a)  Disallowance under section 40(a)(i)-Rs. 21,46,12,294 (b)  Income of the HO/...