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INCOME TAX APPELLATE TRIBUNAL (AHMEDABAD BENCH)
BRR Kumar, Vice President, T. R. Senthil Kumar, Judicial Member
SOPHOS TECHNOLOGIES PRIVATE LIMITED AHMEDABAD – Appellant
Versus
THE DCIT CIRCLE-4(1)(1) AHMEDABAD – Respondent
| Table of Content |
|---|
| 1. factual background of apa and ddt payment (Para 2 , 3 , 7) |
| 2. ddt restricted to 10% under india-uk dtaa (Para 4 , 5 , 6) |
| 3. no interest u/s 234b/c on apa incremental income (Para 8 , 9) |
| 4. verify and grant tds credit as claimed (Para 10) |
| 5. appeal allowed; consequential grounds dismissed (Para 11 , 12) |
आदेश/ORDER
PER : T.R. SENTHIL KUMAR, JUDICIAL MEMBER:-
This appeal is filed by the Assessee as against the appellate order dated 30-12-2024 passed by the Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, (in short referred to as “CIT(A)”), arising out of the assessment order passed under section 143(3) r.w.s. 144B of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) relating to the Assessment Year 2016-17.
2. Brief facts of the case is that the assessee is a Private Limited Company provides Network Security Solutions, Contract Software Development and Contract Support Services. For the Assessment Year 2016-17 assessee filed its original Return of Income on 30-11-2016 declaring total income of Rs.148,86,82,230/- and revised return on 27-03-2018 declaring total income of Rs.149,22,97,140/-. The assessee company entered into an Advanc
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