The Appellate Tribunal addressed various issues: 1. Validity of ...

ITAT rules: 1. Proper notice issued for assessment 2. Upholds non-discrimination clause 3. Overseas fees not taxable 4. Interest not taxable under DTAA.

Case Laws Income Tax

June 26, 2024

The Appellate Tribunal addressed various issues: 1. Validity of assessment - Notice u/s 143(2) properly issued. 2. Tax rate for domestic companies - Non-discrimination clause of India-France Tax Treaty upheld. 3. Taxability of data processing fees - Charges to overseas branch not taxable. 4. Taxability of interest paid by branch office - Interest not taxable under DTAA if connected to Permanent Establishment in India. Tribunal ruled in favor of the assessee on all counts, rejecting Revenue's claims.

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The Appellate Tribunal addressed various issues: 1. Validity of ...

ITAT rules: 1. Proper notice issued for assessment 2. Upholds non-discrimination clause 3. Overseas fees not taxable 4. Interest not taxable under DTAA.

Case Laws Income Tax

June 26, 2024

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