Shah Rukh Khan Prevails in Tax Dispute as ITAT Dismisses Case Over RA.One Earnings

Background of the Tax Case
The case centers on Shah Rukh Khan’s earnings from his 2011 film RA.One, produced under his banner, Red Chillies Entertainment. According to the agreement, 70% of the filming took place in the UK, which meant that a considerable portion of his remuneration—estimated at Rs 83.42 crores—was subject to UK taxes, including withholding tax. Khan declared this income in his original tax return for the Assessment Year 2012-13, claiming a Foreign Tax Credit (FTC) to offset the taxes paid abroad against his Indian tax liability.
ITAT’s Ruling: A Triumph for Shah Rukh Khan
The ITAT bench, consisting of Sandeep Singh Karhail and Girish Agrawal, ruled that the reassessment proceedings were invalid. The tribunal stated that the assessing officer failed to present “fresh tangible material” to justify reopening the case after the statutory deadline. Additionally, the bench highlighted that Khan had fully disclosed his foreign income and tax credits in his original filing, which had already undergone scrutiny under Section 143(3).