Mitsubishi-group company engaged in Sogo Shosha activities did not deduct TDS from payments for purchases made to different group companies incorporated in Japan, Singapore, US, Thailand, in view of difference of opinion between Judges in respect of assessee’s TDS obligations, matter was placed before Chief Justice for appropriate order. (AY. 2006-07)
CIT v. Mitusubishi Corporation India (P.) Ltd. (2018) 252 Taxman 31 (Delhi)(HC) Editorial: Mitusubishi Corporation India (P.) Ltd. v.ACIT (2014) 62 SOT 58 (URO) / 41 taxmann.com 162 ( Delhi) (Trib)
S.40(a)(ia):Amount not deductible- Deduction at source-Purchase made from different group companies –Difference opinion – Matter was referred to Chief Justice for appropriate order -DTAA-India Japan –USA [ S.9(1)(i), 90, 195,Art ,24 ]