Court :
ITAT Mumbai
Brief :
This appeal in ITA No.834/Mum/2019 for A.Y.2015-16 preferred by the order against the final assessment order passed by the Assessing Officer dated 28/11/2018 u/s.143(3) R.W.S. 144C(13) of the Income Tax Act 1961, hereinafter referred to as Act, pursuant to the directions of the ld. Dispute Resolution Panel-1(WZ), Mumbai (DRP in short) u/s.144C(5) of the Act,1961 dated 04/09/2018 for the A.Y.2015-16
Citation :
ITA No.834/Mum/2019
IN THE INCOME TAX APPELLATE TRIBUNAL (VIRTUAL COURT) ‘I’ BENCH MUMBAI
BEFORE SHRI M.BALAGANESH, AM
&
SHRI RAM LAL NEGI, JM
ITA No.834/Mum/2019
(Assessment Year :2015-16)
M/s. Buro Happold Ltd., Famous Studio Lane Dr. E Moses Road Mahalaxmi Mumbai, Maharashtra-400001
PAN/GIR No.AABCB9239Q
(Appellant)
Vs.
DCIT(IT)-1(3)(2) Mumbai
(Respondent)
Assessee by Shri Vijay Mehta & Shri Anuj Kisnadwala - AR
Revenue by Shri Sanjay Singh – CIT DR
Date of Hearing 27/08/2020 & 18/12/2020
Date of Pronouncement 30/12/2020
O R D E R
PER M. BALAGANESH (A.M):
This appeal in ITA No.834/Mum/2019 for A.Y.2015-16 preferred by the order against the final assessment order passed by the Assessing Officer dated 28/11/2018 u/s.143(3) R.W.S. 144C(13) of the Income Tax Act 1961, hereinafter referred to as Act, pursuant to the directions of the ld. Dispute Resolution Panel-1(WZ), Mumbai (DRP in short) u/s.144C(5) of the Act,1961 dated 04/09/2018 for the A.Y.2015-16
2. The assessee had raised the following grounds of appeal:-
1. Ground No.1- Taxability of amount received as common cost recharge as Royalty and fees for technical services (FTS)
1.1. On the facts and in the circumstances of the case and in law, the learned DRP(Dispute Resolution Panel) and DCIT have erred in considering common cost recharge as royalty and Fees for technical services (FTS) as per Article 13 of the India-UK Double Taxation Avoidance Agreement („DTAA‟)
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