Income tax appeal concerning eligibility under Section 144C for a Cyprus-incorporated assessee, dismissed in light of a prior co-ordinate Bench decision in Rolland Enterprises Ltd., with liberty to the Assessing Officer to demonstrate non-eligibility in accordance with law if justified.
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$~67
versus M/S EICR (CYPRUS) LTD. .....Respondent Through: Mr. Vaibhav Kulkarni, Mr. Himanshu Aggarwal & Mr. Yash Nagar, Advocates.
CORAM:
HON'BLE MR. JUSTICE DINESH MEHTA HON'BLE MR. JUSTICE VINOD KUMAR
CM APPL. 22096/2026 (delay in re-filing)
ITA 291/2026
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Ltd.(Supra) is pending before Hon’ble the Supreme Court being SLP (Civil) Diary no. 68355/2025.
DINESH MEHTA, J.
VINOD KUMAR, J.
APRIL 7, 2026/ nk
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1 issue framed by the court
Whether the Cyprus-incorporated respondent-assessee is an eligible assessee under Section 144C(1) of the Income Tax Act, 1961.
Colour shows how this judgement treated each authority
The Commissioner of Income Tax-International Taxation-3 v. Rolland Enterprises Ltd.Followed¶7
ITA 556/2024 (The Commissioner of Income Tax-International Taxation-3 v. Rolland Enterprises Ltd.), decided 02.12.2024
2 provisions across 1 enactments
Commissioner of Income Tax, International Taxation-1, Delhi
M/s EICR (Cyprus) Ltd.
Dinesh Mehta
Vinod Kumar
As recorded by the court registry
Judgements on the same questions, provisions and authorities, from every court
