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INCOME TAX APPELLATE TRIBUNAL (MUMBAI BENCH)
C.V. BHADANG, President, Vikram Singh Yadav, Accountant Member
Bobst Bielefeld GmbH – Appellant
Versus
Asst. Commissioner of Income Tax – Respondent
| Table of Content |
|---|
| 1. assessee's return filing and assessment under limited scrutiny on double taxation relief (Para 2 , 3 , 4 , 5) |
| 2. claim for dtaa benefits on fts at 10% despite business head reporting (Para 6 , 7) |
| 3. cit(a) upholds ao citing limited scrutiny limits and assessee's return declarations (Para 8 , 9) |
| 4. ao erred by allowing ineligible s.91 relief and exceeding scrutiny scope (Para 10 , 11 , 12) |
| 5. appellate stage permits examining legitimate treaty claims beyond limited scrutiny (Para 13 , 14 , 15 , 16) |
| 6. appeals remanded to cit(a) for both ays (Para 17 , 18) |
ORDER
PER VIKRAM SINGH YADAV, A.M :
These two appeals are filed by the assessee against the respective orders of the Learned Commissioner of Income Tax (Appeals)-55, Mumbai [„Ld.CIT(A)‟], both dated 15-07-2025, pertaining to Assessment Years (AYs.) 2017-18 & 2018-19, wherein the assessee has taken the following grounds of appeal:
Grounds of appeal (AY. 2017-18):
1. Ground No. 1 - General On the facts and in the circumstances of the case and in law, Ld. CIT(A) has erred in upholding the assessment order passed by the Learned Assessing Officer ('Ld. AO'), which resulted in determining income tax liability to INR 53,19,994 on
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