undertaken by the assessee, namely, Budge Budge Project,
Calcutta, two Pipeline IOCL Project, Calcutta, and Rihand Project
Sonbhadra, UP.
However, the assessment was completed ... pressed)
11 IOCL/Haldia &
Bholpur Pipeline
Project
Double taxable of N.A. N.A. N.A. N.A. N.A. 4 N.A.
same
M/S Sumitomo Corporation, New Delhi vs Dcit (International Taxation), New ... on 1 July, 2019
related to the taxpayer; that the
taxpayer has obtained a project of "Soil Health Card" from Anand
Agriculture University, Government of Gujarat ... value for computing the
losses out of the said project and it would lead to double taxation.
We are of the considered view that when
projects being executed by the company with Karnataka Power Corporation Ltd. (Raichur Project) and with Tamil Nadu Electricity Board (Basin Bridge Project) there ... assessee had a PE in respect of its Raichur Project and Basin Bridge Project cannot lead to the conclusion or cannot be extended
account of Atul Agro Oils and Alwar Agro has resulted in double addition, as income from contracts executed with these two other parties have been ... double taxation of the same income.
6.2 The learned counsel made the submissions with regard to the additions confirmed in relation to the various projects
assessee has earned income
from foreign projects in Oman, Mauritius, Netherlands and Tanzania.
Income pertaining to these projects has not been included in the taxable ... India under the provisions of respective DTAAs.
The total income from these projects is as under :-
Oman Rs.19,109,894
Mauritius
Dcit, Circle-7(1), Delhi vs Dlf Limited, Delhi on 23 April, 2025
IN THE
Dlf Limited,New Delhi vs National Faceless Assessment Centre, ... on 23 April, 2025
IN THE
Article 5 of the
Double Tax Avoidance Agreement between India and Korea ('the
Treaty'), in the form of project office in India ... project (as per
requirement of Cl. 7.3) and a copy of permission from Reserve
Bank of India for opening Project Office in India
project office in India at Rs. 1,74,99,350. While filing the return, the assessee declared entire income from Chamera project as attributable ... assessee submitted that the profit arising out of Chamera project is to be bifurcated between Head Office in Canada and PE in India
