Hareon Solar Singapore Pvt. Ltd. v. DCIT
Case No: ITA No.2226/Del/2024
Court: Income Tax Appellate Tribunal, Delhi Benches
Date: 1/30/2026
Parties Involved
appellantHareon Solar Singapore Pvt. Ltd.
respondentDCIT
Facts Summary
The case involves Hareon Solar Singapore Pvt. Ltd., a company incorporated in Singapore, claiming tax residency in Singapore and seeking exemption from Indian tax on capital gains from the sale of equity shares and CCDs in an Indian company, Renew Solar Energy (Karnataka) Pvt. Ltd. The Assessing Officer (AO) denied the exemption, arguing that the company was a shell entity created to exploit the India-Singapore Double Taxation Avoidance Agreement (DTAA). The AO noted that the company had minimal…
Decision in favour of
Revenue
Legal Issues
- 1. Whether the final assessment order passed by the Deputy Commissioner of Income Tax and directions issued by the Dispute Resolution Panel are erroneous on facts and bad in law.
- 2. Whether the AO and the Panel erred on the taxability of capital gains arising from the transfer of securities under the provisions of the Income-tax Act, 1961 and the India-Singapore DTAA.
Precedents Relied Upon
12 precedents cited in this judgement.