Disallowance on account of non-deduction of tax can be removed under non-discriminatory clause of India-Japan DTAA

By CA Saurabh Chokhra Income Tax Judiciary September 2, 2015

Case Name: Mitsubishi Corporation India Vs DCIT (ITAT Delhi)
Appeal Number: Only available for paid members
Date of Judgement/Order: Only available for paid members
Courts: All ITAT, ITAT Delhi

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Advertisement Income Tax Return due date extended to 7th September 2015 Brief of the case: The ITAT New Delhi in the case of Mitsubishi Corporation India has ruled that the non-discriminatory clause is not applicable only for the limited purpose of transfer pricing adjustments and other additions to income can be removed by taking benefit of non-discriminatory clause of India-Japan DTAA. Facts of the case: Assessee company made purchases from its associated enterprise Mitusubishi Corporation Japan (MCJ) and its branches. Assessee remitted the payment on account of purchases to MCJ without ...

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