IN THE MADRAS HIGH COURT

C. SARAVANAN, J.

Shriram Capital Ltd. v. DIT & ITO

WP No. 845 of 2012

19 May, 2020

Petitioner by: R. Sivaraman

Respondents by: Hema Muralikrishnan Standing Counsel.

In this Writ Petition, the petitioner has challenged the impugned Order, dated 24-11-2011 passed by the 1st respondent in bearing reference D.C.No.112(2)/264/2011-12.

2. In the impugned order, the 1st respondent has rejected the revision petition filed by the petitioner under Section 264 of the Income Tax Act, 1961, on 6-9-2011, on the ground that there was no undertaking furnished by the petitioner waiving right of appeal before the appropriate appellate forums.

3. The petitioner had entered into an agreement with the abroad company namely M/s. MD IN Services Pvt. Limited in United Kingdom, for getting Insurance Product development. The petitioner was payable to the said abroad company of 2000 pounds per month for the service to be rendered abroad and utilised by the petitioner company abroad.

4. Therefore, the petitioner had sent a letter, dated 24-5-2011 to the 2nd respondent for waiver of interest from deducting tax at source for the payments made to the said non-resident company under Section 195 of the Income Tax Act, 1961.