Disallowance u/s 40(a)(I) of the Income Tax Act is not Applicable as per DTAA between India and Japan: Delhi HC rules in Favour of Mitsubishi Corp India [Read Order]

The Court observed that equal treatment or the non-discrimination Clause obtaining in Articles 24(3) and 26(3) of the India-Japan/India-USA DTAAs would apply with regard to the payment for purchases made by the respondent/assessee.
Disallowance - Income Tax Act - DTAA - Delhi HC - Mitsubishi Corp India - taxscan

In a ruling in favour of Mitsubishi Corporation India P Ltd, the Delhi High Court held that disallowance under section 40(a)(i) of the Income Tax Act, 1961 is not applicable in view of the provision of Double Taxation Avoidance Agreements (DTAAs) entered into by India with Japan and the USA. The appellant/revenue challenged the order…

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