2013 (7) TMI 471

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....ent years are 2004-05, 2005-06, 200607 and 2007-08. The appeals are directed against the orders of the Commissioner of Income-tax (Appeals)-XI at Chennai, all dated July 2, 2009. The appeals arise out of the assessment completed under section 143(3) of the Income-tax Act, 1961. The solitary ground raised by the Revenue for the assessment year 200405 is that the Commissioner of Income-tax (Appea....

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.... also for taxation. Otherwise, it was sufficient for the assessee to offer the interest portion alone, as income for taxation. In these circumstances, we do not find much force in the argument advanced by the Revenue.   Further, if all the contention of the Revenue is accepted and the disallowance is withdrawn, it would be necessary to exclude the principal portion of the lease rental from....

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....cannot be regarded as income from debt claim as per article 11 of the Double Taxation Avoidance Agreement entered into between India and the U. S. A. The finding of the Commissioner of Income-tax (Appeals) is justified in view of the decision of the Income-tax Appellate Tribunal in the case of Vijay Ship Breaking Corporation v. Deputy CIT [2002] 76 TTJ (Rajkot) 169. The relevant observation is ext....