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INCOME TAX APPELLATE TRIBUNAL (BANGALORE BENCH)
Beena Pillai, J, Chandra Poojari, ACJ
M/S. MANN HUMMEL GMBH BENGALURU – Appellant
Versus
DEPUTY COMMISSIONER OF INCOME-TAX INTERNATIONAL TAXATION CIRCLE-1(2) BENGALURU – Respondent
| Table of Content |
|---|
| 1. background of the assessment and tax implications. (Para 2) |
| 2. arguments on the nature of payments and applicability of royalty. (Para 3) |
| 3. court's analysis on the nature of the payment as royalty. (Para 5) |
ORDER
PER BEENA PILLAI, JUDICIAL MEMBER
Present appeal arises out of the order dated 12.07.2023 passed by the Ld.ACIT(International Taxation), Circle – 1(2), Bangalore for A.Y. 2020-21 on following grounds of appeal:
“Based on the facts and circumstances of the case and in law, Mann Hummel GMBH respectfully craves leave to prefer an appeal against the assessment order passed by the Deputy Commissioner of Income-tax, International Taxation Circle — 1(2), Bengaluru (hereinafter referred to as the "learned AO") dated 12 July 2023, under section 143(3) read with section 144C(13) of the Income-tax Act, 1961 ("the Act") on the following grounds:
1. The order of the learned AO is based on incorrect interpretation of law and therefore is bad in law.
2. The learned AO and the Hon'ble Dispute Resolution Panel ("DRP") erred, in law and on facts, by holding that the payment received towards cross charge of lease line / Global Area Network (-GAN") charges, amounting to INR 49,5
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