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Axalta Coating Systems Dutch Holding BBV Vs. ACIT

Case No: ITA Nos.3038, 3039 & 3040/Del/2022
Court: Income Tax Appellate Tribunal, Delhi Bench
Date: 3/26/2025

Parties Involved

appellantAxalta Coating Systems Dutch Holding BBV
respondentACIT, Circle Intl. Taxation 1(1)(1), New Delhi

Facts Summary

The appellant, Axalta Coating Systems Dutch Holding BBV, filed appeals against the order of the Commissioner of Income Tax (Appeals), Delhi, which upheld the rejection of the appellant's rectification application filed under Section 154 of the Income-tax Act, 1961. The rectification application sought to correct the tax rate on interest income from 10% to 5%, as per Section 115A read with Section 194LC of the Act. The appellant argued that it had satisfied all conditions for claiming the lower t

Decision in favour of

Assessee

Legal Issues

  • 1. Whether the appellant filed a proper rectification application under Section 154 of the Act.
  • 2. Whether the appellant is entitled to the lower tax rate of 5% on interest income under Section 115A read with Section 194LC of the Act.

Precedents Relied Upon

3 precedents cited in this judgement.

Judgment Outcome

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