The ITAT overturned the tax department’s reassessment of Khan’s income, ruling it legally unjustified.
Actor Shah Rukh Khan has won a significant victory against the Income Tax authorities in his dispute over foreign tax credit claims. The Income Tax Appellate Tribunal (ITAT) has overturned the tax department’s decision to reassess his case for the 2011-12 financial year.
The dispute stemmed from Khan’s earnings from his 2011 film RA One, with tax authorities challenging his reported income of ₹83.42 crore and rejecting his foreign tax credit claims for taxes paid in the UK. The department reassessed his income at ₹84.17 crore—more than four years after the relevant assessment year, 2012-13.
The ITAT overturned the tax department’s reassessment of Khan’s income, ruling it legally unjustified.
At the core of the dispute was Khan’s agreement with Red Chillies Entertainment, which stipulated that 70% of the film’s shooting would take place in the UK. Accordingly, 70% of his earnings were subject to UK taxation, including withholding tax, with payments routed through Winford Production, a UK-based entity. The tax department argued that this arrangement resulted in a revenue loss for India and denied his foreign tax credit claims.
The ITAT bench, comprising Sandeep Singh Karhail and Girish Agrawal, reportedly ruled that the reassessment was invalid, stating that the assessing officer had failed to present any fresh tangible material to justify reopening the case beyond the statutory four-year period. The tribunal also noted that the issue had already been reviewed during the initial scrutiny, making the reassessment legally flawed on multiple grounds.
RA One amassed a gross worldwide collection of ₹206.73 crore, according to Sacnilk, a box office data provider.
Shah Rukh Khan is currently working on his upcoming film King, which will also star his daughter, Suhana Khan. Production is set to begin in March 2025, with a global release planned for 2026. Meanwhile, he was in Jaipur last night attending the 25th edition of the IIFA Awards.
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