Penalty under sec 271(1)(C) cannot be imposed either for concealment or furnishing inaccurate particulars
Court :
INCOME TAX APPELLATE TRIBUNAL
Brief :
The relevant facts of the case are that the assessee is a company incorporated in Thailand and was engaged in the business of providing digital broadcast service through its transponders to its customers including Indian residents. For the years under appeal, the assessee declared NIL income in the return filed by it. The claim of the assessee was that its receipt from the business of providing transponder services was in normal course of carrying on business and, therefore, constituted “business profits” in the hands of the assessee. Further, since the assessee did not have a permanent establishment in India, its business profits were not liable to tax in India as per Article 7 of the DTAA between India and Thailand
Citation :
JDIT, Intl. Taxation, Circle 2(2),New Delhi. (Appellant)Vs. Shin Satellite Public Co. Ltd.,C/o Mohinder Puri & Co.,1A-D, Vandana, 11,Tolstoy Marg, New Delhi.AAGCS4481E(Respondent)
You have reached your daily limit of 2 Free Judgements
Subscribe to CCI PRO for unlimited access
Why Upgrade to CCI PRO?
- No Ads
- WhatsApp Community
- Daily E-Newsletter
- Unlimited Judgements Access
- Profile Visitors
- Link Social Profiles
- Featured Job Posts
- Pro Badge
- Expert GST Guidance
- Unlimited Forum Replies
- Download Content in PDF
Already a PRO member? Login here for an ad-free experience. 011-411-70713
Ayush
Published in Income Tax
Views : 2849
Comments
Trending Online Classes
-
DT & Audit (Exam Oriented Fastrack Batch) - For May 26 Exams and onwards Full English
CA Bhanwar Borana & CA Shubham Keswani
Browse by Category
Article Assistant
MANUJ SHARMA AND COMPANY
Noida
CA Inter
View Details
Industrial Trainee
Twenty Point Nine Five Ventures Private Limited
Noida
CA Inter
View Details
CCI
Pro
CAclubindia
