2024 (1) TMI 1402 - SCH - Income Tax

Reopening of assessment u/s 147 - Unexplained gain on sale of shares of company abroad - assessee claimed gains earned by it on sale of Agile shares were not taxable in India by virtue of Article 13(4) the DTAA entered into and subsisting between India and Singapore ( India-Singapore DTAA ) based on the Tax Residency Certificate ( TRC ) - Relevance of information from a third party - borrowed satisfaction - As decided by HC 2023 (2) TMI 35 - DELHI HIGH COURT no income chargeable to tax has escaped assessment in the present case HELD THAT - Delay condoned. Leave granted. Hearing expedited. List in the month of March, 2024. There shall be stay of the impugned judgment of the High Court. In the meanwhile, the Revenue shall not proceed to collect the amount assessed to be collected from the respondent.

Summary

The Supreme Court of India granted leave, expedited the hearing, and stayed the impugned judgment of the High Court. The Revenue was barred from collecting the assessed amount from the respondent until further notice. The case was listed for March 2024.