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Documents citing Commissioner Of Income-Tax vs Clough Engineering Ltd. on 26 October, 2007

Bank Of Nova Scotia, Mumbai vs Deputy Commissioner Of Income Tax ... on 28 February, 2024

The above decision answers the objection raised by the ld. Departmental Representative. The Hon'ble High Court affirmed the view of Special Bench in Asstt.CIT vs. Clough Engg.Ltd, 11 taxmann.com 70 (Delhi -SB) that interest on income tax refund is not effectively connected with the PE. The Hon'ble High Court further clarified that such interest is taxable under Article 11(2) of Indo- Netherlands tax treaty.
Income Tax Appellate Tribunal - Mumbai Cites 22 - Cited by 0 - Full Document

Dcit (It) -1(2)(1), Mumbai vs The Bank Of Nova Scotia, Mumbai on 28 February, 2024

The above decision answers the objection raised by the ld. Departmental Representative. The Hon'ble High Court affirmed the view of Special Bench in Asstt.CIT vs. Clough Engg.Ltd, 11 taxmann.com 70 (Delhi -SB) that interest on income tax refund is not effectively connected with the PE. The Hon'ble High Court further clarified that such interest is taxable under Article 11(2) of Indo- Netherlands tax treaty.
Income Tax Appellate Tribunal - Mumbai Cites 22 - Cited by 0 - Full Document

Bank Of Nova Scotia, Mumbai vs Addl Dit (It) Rg 3, Mumbai on 28 February, 2024

The above decision answers the objection raised by the ld. Departmental Representative. The Hon'ble High Court affirmed the view of Special Bench in Asstt.CIT vs. Clough Engg.Ltd, 11 taxmann.com 70 (Delhi -SB) that interest on income tax refund is not effectively connected with the PE. The Hon'ble High Court further clarified that such interest is taxable under Article 11(2) of Indo- Netherlands tax treaty.
Income Tax Appellate Tribunal - Mumbai Cites 22 - Cited by 0 - Full Document

The Bank Of Nova Scotia, Mumbai vs Dcit (It) -1(2)(1), Mumbai on 28 February, 2024

The above decision answers the objection raised by the ld. Departmental Representative. The Hon'ble High Court affirmed the view of Special Bench in Asstt.CIT vs. Clough Engg.Ltd, 11 taxmann.com 70 (Delhi -SB) that interest on income tax refund is not effectively connected with the PE. The Hon'ble High Court further clarified that such interest is taxable under Article 11(2) of Indo- Netherlands tax treaty.
Income Tax Appellate Tribunal - Mumbai Cites 22 - Cited by 0 - Full Document

The Bank Of Nova Scotia, Mumbai vs Dcit (It)-1(2)(1), Mumbai on 28 February, 2024

The above decision answers the objection raised by the ld. Departmental Representative. The Hon'ble High Court affirmed the view of Special Bench in Asstt.CIT vs. Clough Engg.Ltd, 11 taxmann.com 70 (Delhi -SB) that interest on income tax refund is not effectively connected with the PE. The Hon'ble High Court further clarified that such interest is taxable under Article 11(2) of Indo- Netherlands tax treaty.
Income Tax Appellate Tribunal - Mumbai Cites 22 - Cited by 0 - Full Document

Natwest Markets Plc,Kolkata vs Assistant Commissioner Of Income Tax, ... on 27 November, 2024

In this regard reliance is placed on the order of Special Bench of the Tribunal in CIT vs. Clough Engineering Limited 130 ITD 137 as well as the judgment of the Bombay High Court in DIT vs. Credit Agricole Indozuez 377 ITR 102. In both these decisions the Tribunal/Court has taken the view that the interest earned from the tax department has to be assessed in accordance with Article 11(2) of the relevant DTAA.
Income Tax Appellate Tribunal - Kolkata Cites 16 - Cited by 0 - Full Document

Natwest Markets Plc - India ... vs Cit (It & Tp), Cir- 1(2), Kolkata, ... on 26 August, 2025

In this regard reliance is placed on the order of Special Bench of the Tribunal in CIT vs. Clough Engineering Limited 130 ITD 137 as well as the judgment of the Bombay High Court in DIT vs. Credit Agricole Indozuez 377 ITR 102. In both these decisions the Tribunal/Court has taken the view that the interest earned from the tax Page | 5 ITA No.997/KOL/2024 Natwest Markets PLC_India Branch; A.Y. 2018-19 department has to be assessed in accordance with Article 11(2) of the relevant DTAA.
Income Tax Appellate Tribunal - Kolkata Cites 15 - Cited by 0 - Full Document

Zest Aromas Pvt. Ltd.,, Baroda vs Assessee on 2 January, 2012

The learned counsel of the assessee also relied on the decision of the Hon'ble Allahabad High Court in the case of Amit Vegetables Ltd. vs. CIT [158 Taxman 36] and the decision of Hon'ble Uttrakhand High Court in the case of CIT vs. Clough Engineering Ltd. [300 ITR 435], wherein it was held that assessment order cannot be treated as erroneous on the ground that the assessee had not filed audit report along with the return of income. Concluding his arguments, the learned counsel of the assessee submitted that the order passed by the learned CIT u/s 263 of the Act be quashed.
Income Tax Appellate Tribunal - Ahmedabad Cites 22 - Cited by 0 - Full Document

Aker Solutions India Sdn Bhd, Mumbai vs Dy Commissioner Of Income Tax ... on 7 November, 2022

(a) The Tribunal by the impugned order restored the issue of the rate at which interest is to be charged to tax on income-tax refund received under Section 244A of the Act to the Assessing Officer to be decided in the light of Indo-France DTAA and the decision of the Special Bench of the Tribunal in the matter of Asstt. CIT v. Clough Engg. Ltd. [2011] 130 ITD 137/11 Taxman 70 (Delhi).
Income Tax Appellate Tribunal - Mumbai Cites 5 - Cited by 0 - Full Document
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