Director Of Income Tax (International Taxation), Kolkata v. M/S. Abn Amro Bank Nv

O-140 & 141 IN THE HIGH COURT AT CALCUTTA SPECIAL JURISDICTION (INCOME TAX) ORIGINAL SIDE ITA/19/2012 DIRECTOR OF INCOME TAX (INTERNATIONAL TAXATION), KOLKATA VS. M/S. ABN AMRO BANK NV ITA/33/2012 DIRECTOR OF INCOME TAX (INTERNATIONAL TAXATION), KOLKATA VS. THE ROYAL BANK OF SCOTLAND BEFORE : THE HON’BLE JUSTICE T.S. SIVAGNANAM And THE HON’BLE JUSTICE HIRANMAY BHATTACHARYYA Date : 22[nd] November, 2022 Appearance : Ms. Smita Das De, Adv. …for the appellant in ITAT 19 of 2012. Mr. Smarajit Roychowdhury, Adv. …for the appellant in ITAT 33 of 2012. Mr. Asit Kr. De, Adv. …for the respondents. The Court : We have heard the learned standing counsel appearing for the appellant/revenue and the learned counsel for the respondent/assessee. Learned counsel for the respondent/assessee submitted that the assessee has availed the benefit of the “Vivad Se Vishwas Scheme” and Form V has been issued recording the same. The appeals stand disposed of and the substantial questions of law are left open. (T.S. SIVAGNANAM, J.) (HIRANMAY BHATTACHARYYA, J.) s.pal/SN.