Home Case Index All Cases Income Tax Income Tax + AT Income Tax - 2019 (12) TMI AT This
Forgot password New User/ Regiser ⇒ Register to get Live Demo
2019 (12) TMI 30 - ITAT DELHIOrder u/s. 201(1)/ 201 (1A) - whether interest payable by the assessee u/s. 201 (1A) does not arise as the income tax was assessed in the hands of the foreign company which was done by the revenue authority by passing assessment order in M/s. Formula One World Championship Ltd. and has been taxed in the hands of the foreign entity - HELD THAT:- Since the foreign company i.e. Formula One Championship Ltd. [2016 (12) TMI 123 - DELHI HIGH COURT] has already been taxed and the Hon’ble Supreme Court [2017 (4) TMI 1109 - SUPREME COURT] has confirmed the same in foreign company’s case, it will be appropriate to remand back this issue for modifying the demand if any arise after verifying the records as per decisions of the Hon’ble Supreme Court in foreign company’s case, as the assessee has already deducted the TDS and paid the same with interest. Needless to say the assessee be given an opportunity of hearing by following the principles of natural justice. Ground No.2 and 3 are partly allowed for statistical purposes.
|