IN THE INCOME TAX APPELLATE TRIBUNAL “I” BENCH, MUMBAI BEFORE SMT. BEENA PILLAI (JUDICIAL MEMBER)

AND SHRI RENU JAUHRI (ACCOUNTANT MEMBER)

I.T.A. No.4813/Mum/2023 Assessment Year: 2021-22 Loparex Holding BV Assistant

901-902, First Avenue, Commissioner of

9th Floor, Goregaon- Income-tax Mulund Link Road, International Near Inorbit Mall, Vs. Taxation, Malad West, Circle – 3(1)(2), Mumbai – 400 064 Mumbai PAN: AAECL3546M (Appellant) (Respondent)

Appellant by None Respondent by Shri Krishna Kumar, SR. D.R.

Date of Hearing 19.02.2025 Date of Pronouncement 28.02.2025 ORDER Per: Smt. Beena Pillai, J.M.:

The Present appeal filed by the assessee is against the final assessment order dated 27/10/2023 passed by ACIT International taxation Circle (1)(2), Mumbai for assessment year

2021-22 on following grounds:

“1.1. The Ld. AO has erred in finalizing an order of assessment which suffers from legal defects and is erroneous such as being passed without adequate inquiries and as such is liable to be quashed.

1.2. The lower authorities have erred in taxing the dividend income of the Appellant amounting to INR 26,99,97,500 at 10% as per Article 10 of the India-Netherlands DTAA.

1.3. The lower authorities hav