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2020 (8) TMI 849 - AT - Income TaxApplicability of provisions of section 206AA - payments made to non-resident entities - A.O. had also invoked section 206AA of the Act while initiating proceedings u/s 201(1) and 201(1A) - CIT(A) held that section 206AA is not applicable to non-resident entities to whom provisions of DTAA is applicable. Aggrieved, the revenue has filed these appeals before us - HELD THAT:- As noticed that the coordinate bench in M/S. BHARATH FRITZ WERNER LTD. [2020 (6) TMI 669 - ITAT BANGALORE] has followed the decision rendered in the case of Nagarjuna Fertilisers & Chemicals Ltd. [2017 (3) TMI 81 - ITAT HYDERABAD] and in the case of Danisco India Private Ltd.[2018 (2) TMI 1289 - DELHI HIGH COURT] in holding that the provisions of sec.206AA of the Act would not apply to a recipient of income, who is by the DTAA entered by India and his country. We notice that the Ld CIT(A) has decided this issue on identical lines. Accordingly, we uphold the view taken by Ld. CIT(A) on this issue. - Decided against revenue.
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