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Case Law Details

Case Name : BLPL Singapore Pvt Ltd Vs DCIT (ITAT Mumbai)
Appeal Number : ITA No. 605/Mum/2023
Date of Judgement/Order : 22/05/2023
Related Assessment Year : 2018-19
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BLPL Singapore Pvt Ltd Vs DCIT (ITAT Mumbai)

BLPL Singapore Pvt Ltd has filed an appeal against the Assessing Officer’s order under Section 270A of the Income Tax Act, 1961 for the Assessment Year 2018-19. The appeal pertains to the non-disclosure of interest income while computing the total income for taxation purposes.

Analysis: The Assessing Officer added Rs. 3,51,94,864/- to the total income and taxed it at 15% based on the Double Taxation Avoidance Agreement (DTAA) with Singapore. A penalty of Rs. 26,39,615/- was levied under Section 270A for the non-disclosure of interest income. The appeal was filed before the Hon’ble Tribunal.

Conclusion: The ITAT Mumbai dismissed the appeal, stating that the appeal should have been filed before the Commissioner of Income Tax appeals under Section 253(1)(a) of the Act, and not before the Appellate Tribunal. The penalty order passed by the Assessing Officer stands upheld.

FULL TEXT OF THE ORDER OF ITAT MUMBAI

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