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2013 (11) TMI 116 - AT - Income TaxDisallowance of reinsurance premium paid to non-resident reinsurance companies – GE India Technology Cen. (P.) Ltd. v. CIT [2010 (9) TMI 7 - SUPREME COURT OF INDIA] - assessee contended that Reinsurance premium paid to non-resident reinsurance companies directly, where DTAA exists, and they having no place of permanent establishment in India, cannot be disallowed in the hands of the assessee under section 40(a)(i), as they are not liable to tax in India - Held that:- many of the fine details now placed by the assessees before us, were not available before the lower authorities - matter remanded back for de novo disposal in accordance with law after giving the assessees reasonable opportunity of being heard.
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