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The Bank of Tokyo-Mitsubishi Ltd. vs. The Additional Commissioner of Income Tax, Special Range-3, Calcutta

Case No: ITA Nos.449/Kol/2001; 2558/Kol/2002 & 7324/Mum/2002
Court: Income Tax Appellate Tribunal, Delhi Bench
Date: 3/19/2025

Parties Involved

appellantThe Bank of Tokyo-Mitsubishi Ltd.
respondentThe Additional Commissioner of Income Tax, Special Range-3, Calcutta
respondentThe Assistant Director of Income Tax, International Taxation, Kolkata
respondentDy. DIT(IT)-1(1), Mumbai

Facts Summary

The instant batch of three cases pertains to the single assessee, The Bank of Tokyo-Mitsubishi Ltd. The assessee has filed its former appeal ITA No.449/Kol/2001 for AY: 1997-98 against Commissioner of Income Tax (Appeals)-II, Kolkata’s order dated 14.12.2000. The assessee’s and Revenue’s cross-appeals ITA No. 2558/Kol/2002 and 7324/Mum/2002 for AY: 1999-2000 are directed against the CIT(A), Kolkata’s order dated 10.10.2002. The limited issue under consideration is the territorial jurisdiction of the Delhi benches of the Income Tax Appellate Tribunal. The 'situs' of the learned Assessing Authority in both these cases is at Kolkata.

Decision in favour of

Revenue

Legal Issues

  • 1. Territorial jurisdiction of the Delhi benches of the Income Tax Appellate Tribunal.

Judgment Outcome

Decided in favour of Revenue.

Precedents Relied Upon

4 precedents cited in this judgement.

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