General Reinsurance Corporation Vs ACIT (International Taxation)
Case No: ITA No. 1817/MUM/2025
Court: Income Tax Appellate Tribunal, 'I' Bench, Mumbai
Date: 1/7/2026
Parties Involved
appellantGeneral Reinsurance Corporation
respondentACIT (International Taxation), Circle -2(3)(2), Mumbai
Facts Summary
The assessee, General Reinsurance Corporation, filed its return of income for A.Y. 2022-23 declaring income of Rs. 6,92,160/- and claimed a refund of Rs. 99,80,050/- on account of TDS. The case was selected for scrutiny. The assessing officer noted that the assessee is a US-based company providing reinsurance and retrocession services globally. The assessing officer recorded that the assessee had entered into a Quota Share retrocession agreement with its India Branch effective from 01.04.2019. T…
Decision in favour of
Assessee
Legal Issues
- 1. Jurisdiction of the notice issued under section 143(2) of the Act.
- 2. Whether the Indian Branch of General Reinsurance AG constitutes a business connection in India under section 9(1)(1) of the Act.
11 more legal issues analysed in this judgement.
Precedents Relied Upon
9 precedents cited in this judgement.