9911796707
TMI Blog2021 (9) TMI 913X X X X Extracts X X X X X X X X Extracts X X X X ..... il Chaturvedi, AM This appeal filed by the assessee is directed against the order of the Asstt. Commissioner of Income Tax, Circle-2(1)(1), (Intl. Taxn.) New Delhi under section 144C(5) of the Act pursuant to the directions of Dispute Resolution Panel (DRP) - I, New Delhi order dated 29.10.2020 for Assessment Year 2017-18. 2. The relevant facts as culled from the material on records are as under ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... assessee is now in appeal before us and has raised the following grounds: 1. "That in the facts and circumstances of the case & in law, the order passed by the Ld. Assistant Commissioner of Income Tax ("AO") under Section 143(3) read with Section 144C(13) of the Income Tax Act 1961 ("the Act") assessing the income of the Appellant at Rs. 18,34,89,850/- instead of returned income of Rs. 10,67,32, ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e principle of make available as per Article 13(4)(c) of the India UK DTAA and accordingly, erred in holding that the receipts of the Appellant satisfies the make available principle and is to be taxed as FTS under the provisions of India UK DTAA." 4. Before us, at the outset, Learned AR submitted that the issue involved in the present appeal is whether the balance receipts not attributable to pe ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... in the facts of the case in the year under consideration and that of the earlier years, we following the decision of the Co-ordinate Bench of Tribunal in assessee's own case for A.Y. 2010-11 order dated 04.10.2016 and for similar reasons dismiss the appeal of the assessee. Thus the appeal of the assessee is dismissed. 7. In the result, appeal of the assessee is dismissed. Order pronounced in ..... X X X X Extracts X X X X X X X X Extracts X X X X
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