2025 (12) TMI 289

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....Siddesh Chaugule, Adv. (through VC) & Ms. Jyoti Yadav, CA For the Revenue : Srhi M.S. Nethrapal, CIT-DR ORDER PER KRINWANT SAHAY, AM: This bunch of three appeals are by the assessee and they are directed against the order of National Faceless Appeal Centre/Ld. CIT(A), Delhi, all dated 07.10.2024, arising out of assessment orders all dated 27.06.2024 passed u/s 237 of the Income Tax Act....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....ase of DCIT v. Total Oil India (P.) Ltd. [2023] 149 taxmann.com 332 (Mumbai-Trib.) (SB) without appreciating the fact that due to incomplete appreciation of legal history, circulars, memorandum and background of the case an incorrect view has been framed by the Hon'ble Special Bench that the provisions of double taxation avoidance agreement does not get triggered when a domestic company pays D....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....se of Dy. CIT v. Total Oil India P. Ltd., cited in 149 taxmann.com 332. 5. Per Contra, ld. DR agreed with the submission made by the ld. Counsel for the assessee. 6. We have heard the arguments of the ld. Counsel for the assessee and as the grounds of appeal in this case are squarely covered against the assessee by the decision of Special Bench of Mumbai Tribunal in the case of Dy. CIT v. To....