The Commissioner of Income Tax - International Taxation -3 v. Tata Nyk Shipping Pte Ltd.
Case brief
What is this about?
ITA 182/2026; High Court of Delhi; decided 13.03.2026; CIT (International Taxation)-3 v. Tata NYK Shipping PTE Ltd.; appeal under Section 260A of the Income Tax Act, 1961 dismissed; no substantial question of law; Tribunal finding of commercial substance of Singapore entity (commercial assets and operations since 2010; return of income filed) upheld; benefit under India-Singapore Double Taxation Avoidance Agreement; Assessing Officer's conduit-entity finding rejected; related earlier departmental appeal ITA 148/2024 dismissed vide order dated 18.03.2024; coram Dinesh Mehta and Vinod Kumar, JJ.
What did the court decide?
The Tribunal has arrived at a correct conclusion after appreciating the material on record, and the finding recorded by the Tribunal in the previous order has already been upheld by this Court vide its order dated 18.03.2024.