Case Law Details
Case Name : The Prudential Assurance Co. Limited Vs. The Asstt. Director of Income-tax (ITAT Mumbai)
Related Assessment Year : 2003-2004
Courts :
All ITAT ITAT Mumbai
Become a Premium member to Download.
If you are already a Premium member, Login here to access.
Sponsored
In this case, M/s Prudential Assurance Co. Ltd , a tax resident of UK, was denied the benefit of setting off of the business loss from sale of shares against the income from other sources by the Assessing Officer (‘AO’) on the ground that the assessee had no Permanent Establishment in India as per Article 5 of the India-UK Double Taxation Avoidance Agreement . The Honourable Mumbai Tribunal observed that the assessee chose to be ruled by the provisions of the Income Tax Act, 1961 and not DTAA. Thus, the AO was not justified in directing that the business
Please become a Premium member. If you are already a Premium member, login here to access the full content.
Sponsored
Kindly Refer to
Privacy Policy &
Complete Terms of Use and Disclaimer.