https://www.taxtmi.com/highlights?id=94404 The ITAT held that the reassessment initiated u/s 147 was without valid jurisdiction and therefore void. The assessee, a UAE tax resident foreign company, had only interest income from an Indian payer, on which tax had been duly withheld at 12.5% in accordance with Article 11 of the India-UAE DTAA and s.195. As the conditions of s.115A(5) were satisfied, the assessee was not obliged to file a return for AY 2012-13, rendering the AO's sole basis for reopening-non-filing of return-untenable. Further, the AO wrongly taxed double the actual interest income without supporting material. The reassessment order was quashed and the assessee's appeal allowed. en-us Sat, 22 Nov 2025 07:36:35 +0530 Sat, 22 Nov 2025 07:36:37 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=94404 The ITAT held that the reassessment initiated u/s 147 was without valid jurisdiction and therefore void. The assessee, a UAE tax resident foreign company, had only interest income from an Indian payer, on which tax had been duly withheld at 12.5% in accordance with Article 11 of the India-UAE DTAA and s.195. As the conditions of s.115A(5) were satisfied, the assessee was not obliged to file a return for AY 2012-13, rendering the AO's sole basis for reopening-non-filing of return-untenable. Further, the AO wrongly taxed double the actual interest income without supporting material. The reassessment order was quashed and the assessee's appeal allowed. Highlights Income Tax Sat, 22 Nov 2025 07:36:35 +0530 https://www.taxtmi.com/highlights?id=94404