https://www.taxtmi.com/caselaws?id=71299 The tribunal upheld the CIT(A)'s decision to allow the deduction of the loss incurred by the assessee's Japan branch office when computing taxable income in India. The tribunal dismissed the AO's appeal, affirming that the assessee is entitled to taxation on a worldwide basis, disregarding the India-Japan DTAA for this year. It emphasized the independence of each assessment year, allowing the assessee to choose the more beneficial tax treatment annually. The tribunal acknowledged the potential for a "double dip" of losses but deemed it permissible under the current legal framework. en-us Fri, 29 Jun 2007 00:00:00 +0530 Wed, 17 Jan 2024 15:33:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=71299 The tribunal upheld the CIT(A)'s decision to allow the deduction of the loss incurred by the assessee's Japan branch office when computing taxable income in India. The tribunal dismissed the AO's appeal, affirming that the assessee is entitled to taxation on a worldwide basis, disregarding the India-Japan DTAA for this year. It emphasized the independence of each assessment year, allowing the assessee to choose the more beneficial tax treatment annually. The tribunal acknowledged the potential for a "double dip" of losses but deemed it permissible under the current legal framework. Case-Laws Income Tax Fri, 29 Jun 2007 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=71299