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Smit Singapoare Pte Ltd, Mumbai vs Dcit (It) Cir 4(1)(2), Mumbai on 9 November, 2020 cites

Shree Global Tradefin Ltd, Mumbai vs Dcit Cen Cir 5(1), Mumbai on 15 October, 2018

22. The assessee has assailed before us the levy of interest u/ss. 234A and 234B amounting to Rs.40,29,825/- and Rs.96,26,797/-, respectively. The ld. A.R had not placed any contention as to how the charging of the aforesaid respective interests suffered from any infirmity. Be that as it may, as the charging of the respective interests would be consequential to the giving effect of our aforesaid observations on the merits of the case, the A.O shall consider the claim of the assessee in the course of the ITA No.7055/Mum/2017 A.Y. 2014-15 29 Smit Singapore Pte. Ltd. Vs. DCIT (IT)-4(2)(1) ‗set aside' proceedings. The Grounds of appeal Nos. 12 & 13 are allowed for statistical purposes.
Income Tax Appellate Tribunal - Mumbai Cites 401 - Cited by 184 - Full Document

Poompuhar Shipping Corpn. Ltd. vs The Income-Tax Officer, International ... on 23 June, 2006

Accordingly, we are of the considered view, that unlike the facts involved in the aforesaid case before the Hon'ble High Court, in the case before us the control of the ship had throughout remained with the assessee, and the charterer viz. Leighton India Contractor Pvt. Ltd. was only concerned with the services and had no control over the vessel or its crew members. As such, we find that the reliance placed by the lower authorities on the judgment of the Hon'ble High Court of Madras in the case of Poompuhar Shipping Corporation Vs. ITO (I.T)-II Chennai (2014) 360 ITR 257 (Mad), being distinguishable on facts, would thus not assist the case of the revenue. In fact, our aforesaid view stands fortified by order of a co- ordinate bench of the Tribunal i.e ITAT, Chennai in the case of Sical ITA No.7055/Mum/2017 A.Y. 2014-15 25 Smit Singapore Pte.
Income Tax Appellate Tribunal - Chennai Cites 16 - Cited by 10 - Full Document

Asia Satellite Telecommunications Co. ... vs Assistant Dit, International Taxation on 23 August, 2012

35.4 The Court has held that the concept of dominion or control is sine qua non use. Further Explanation 5 below Section 9 (vi), to the extent it is not beneficial to the Assessee, will have to in terms of Section 90 (2) of the Act, make way for the provision of the DTAA which is more beneficial to the Assessee. This aspect too has been clarified by the Court in Asia Satellite Telecommunications (supra). It was observed:
Delhi High Court Cites 26 - Cited by 81 - R V Easwar - Full Document
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