Taxability of Offshore services under DTAA post-amendment in S. 9(1)(vii)

ITAT MUMBAI BENCH ‘L’ IHI Corporation Versus Additional Director of Income-tax (International Taxation) IT Appeal No. 7227 (Mum.) of 2012 [ASSESSMENT YEAR 2009-10] Date of Pronouncement – 13.03.2013 ORDER R.S. Syal, Accountant Member  This appeal by the assessee arises out of the order dated 10.10.2012 passed by the Assessing Officer u/s 143(3) read with section 144C(13) of the Income-tax Act, 1961 (hereinafter also called as ‘the Act’) in relation to the assessment year 2009-2010. 2. First issue in this appeal is against taxability of a sum of Rs....