Mere NMS-triggered email alert without basis cannot justify reassessment: ITAT Delhi

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 triggered 147/148 pro...