ITAT Deletes Global Income Addition After Holding No Basis for POEM in India Despite CIT(A)’s Own Findings

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ITAT Deletes Global Income Addition After Holding No Basis for POEM in India Despite CIT(A)’s Own Findings

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Published on

05/05/2026

By Mariya Paliwala

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The Income Tax Appellate Tribunal (ITAT), Ahmedabad Bench, has set aside the addition of global income made against a foreign-incorporated company after finding that there was no sustainable basis to conclude that its Place of Effective Management (POEM) was in India. The bench of Sanjay Garg (Judicial Member) and Annapurna Gupta (Accountant Member) observed that…

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Mariya Paliwala https://www.jurishour.in/

Mariya is the Senior Editor at Juris Hour. She has 7+ years of experience on covering tax litigation stories from the Supreme Court, High Courts and various tribunals including CESTAT, ITAT, NCLAT, NCLT, etc. Mariya graduated from MLSU Law College, Udaipur (Raj.) with B.A.LL.B. and also holds an LL.M. She started her career as a freelance tax reporter in the leading online legal news companies.

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ITAT Deletes Global Income Addition After Holding No Basis for POEM in India Despite CIT(A)’s Own Findings

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