2024 (10) TMI 1580

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..... in the present case relates to Double Taxation Avoidance Agreement and would therefore fall in the exceptions - HELD THAT:- Firstly, as we accept the argument raised by learned counsel for the respondent with regard to the case not falling within exception to clause l(ii) of para 3.1 which is only with respect to litigation arising out of disputes related to TDS/TCS matters in both domestic and in .....

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..... RAKASH SHARMA, J.(ORAL) 1. Learned counsel for the Revenue has strenuously argued that the case does not fall within the ambit of Circular bearing No. 9/2024 dated 17.09.2024 issued by the Central Board of Direct Taxes on the basis of monetary limit, as the same falls in exception as per para 3.1 of Circular No. 5/2024 dated 15.03.2024. 2. Learned counsel has taken this Court to clause l (ii) of p .....

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..... nsidered the submissions. 6. Firstly, as we accept the argument raised by learned counsel for the respondent with regard to the case not falling within exception to clause l(ii) of para 3.1 which is only with respect to litigation arising out of disputes related to TDS/TCS matters in both domestic and international taxation charges, wherein disputes relating to appeals of international taxation ch .....

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