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Cgi Information Systems vs The Income Tax Officer on 23 January, 2023 cites

The Commissioner Of Income Tax vs M/S Digital Equipment (India) Ltd on 18 August, 2014

The facts of the case of the assessee and of the Digital Equipment (Supra) is identical. In the case of Digital Equipments the assessee company paid taxes in the source country but actually incurred loss when all the admissible deduction in respect of that earning were taken into account. In this case also the assessee company paid withholding taxes in the source country (USA & Canada) and is having losses in India. To quote from the Hon'ble Tribunal's decision, "in the case before us the assesses company had paid taxes in respect of that earning only in one country i.e., United States and claim losses, on taking into account the admissible deduction there from, in the other country, i.e., India. This is surely not, by any stretch of logic of a case of double taxation of income." The ratio of the judgment of the Hon'ble Tribunal is that if any income is not taxable in India, the refund of withholding taxes cannot be granted to the assessee in
Karnataka High Court Cites 0 - Cited by 0 - Full Document
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