IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “I”, MUMBAI BEFORE MS. PADMAVATHY S, ACCOUNTANT MEMBER AND SHRI RAJ KUMAR CHAUHAN, JUDICIAL MEMBER ITA NO. 832/MUM/2024(A.Y: 2018-19)

iSAT Africa Limited FZC Vs. The Deputy Commissioner Office No. 5 Pre-Fab, C Phase II, of Income Tax Fujairah Free Zone Fujairah, Dubai, International Tax Circle-

United Arab Emirates, Dubai - 2(2)(2)

999999 Mumbai, Maharashtra.

PAN – AAGCI8661Q (Appellant) (Respondent)

Assessee Represented by : Shri Dinesh Kukreja, Ld. AR Department Represented by : ShriKrishna Kumar, Ld. DR Date of conclusion of Hearing : 19.06.2025 Date of Pronouncement : 22.09.2025

O R D E R

PER RAJ KUMAR CHAUHAN (J.M.):

1. This appeal is filed by the appellant/assessee against thefinal assessment order dated 16.01.2024 passed u/s 143(3) r.w.s 144C(13) of the Income Tax Act, 1961 („the Act‟), in pursuant to the direction of Ld. Dispute Resolution Panel-1, Mumbai-2 (Ld. DRP) u/s 144C(5) of the Act for AY.

2018-19.

2. The brief facts as culled out from the order of authorities below are that theassesseei.e.ISAT Africa Ltd FZC is a Non-Resident entity, tax resident in UAE. As per the official website, it is involved in the business of providin