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Asstt. CIT (IT)-3(1)(2) Vs. Kuwait Investment Authority

Case No: ITA No. 5351/MUM/2025
Court: Income Tax Appellate Tribunal Mumbai Bench
Date: 1/30/2026

Parties Involved

appellantAsstt. CIT (IT)-3(1)(2)
respondentKuwait Investment Authority

Facts Summary

This appeal by the Revenue is directed against the order dated 20.06.2025 passed by the Ld. Commissioner of Income-tax-57, Mumbai for assessment year 2023-24. The Revenue contends that the assessee, Kuwait Investment Authority (KIA), ought to be assessed as a trust since a Permanent Account Number (PAN) was issued in that status. However, the learned Commissioner of Income-tax (Appeals) accepted the assessee as a corporate entity. The assessee is a non-resident entity constituted under Law No. 4

Decision in favour of

Partly Assessee / Partly Revenue

Legal Issues

  • 1. Whether the assessee should be assessed in the capacity of a trust as mentioned in the PAN obtained by the assessee or as a corporate entity for the purpose of the assessment for tax purposes in India.

Precedents Relied Upon

2 precedents cited in this judgement.

Judgment Outcome

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