Supreme Court · 2021 INSC 495 · Decided 17 September 2021
Director of Income Tax, New Delhi v. M/S Mitsubishi Corporation
- Court
- Supreme Court of India
- Citation
- 2021 INSC 495 · [2021] 7 S.C.R. 750
- Case number
- CIVIL APPEAL No. 1262/2016
- Decided
- 17 September 2021
- Bench
- L. NAGESWARA RAO, ANIRUDDHA BOSE (2-judge bench)
- Outcome
- Disposed off
- Case type
- Civil
- Acts & sections cited
- Income Tax Act Section 190, 201, 209, 234B
Headnote
Income Tax Act, 1961 - ss.190, 201, 209 and 234B - Proviso to s.209(1)(d), inserted by the Finance Act, 2012 - Interpretation of s.209 (1)(d) - The Respondent- Assessee is a non-resident company incorporated in Japan, with operations in India to the Respondent-Assessee u/s. 143 (2) of the Act on 12.10.2006 - An assessment order was passed for the years 1998- 99 to 2004-05 holding that a portion of the Assessee's income was attributable to its activities in India and was therefore liable to be taxed in India, under Articles
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