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2014 (11) TMI 1083 - AT - Income Tax‘Royalty’ and ‘Fees for Technical Services’ under Section 9(1)(vi) and 9(1)(vii) - Held that:- Once the preceding years were awaiting adjudication at the AO stage, it would be inappropriate for us, to come to any conclusion. We, therefore, set aside the orders of the revenue authorities and restore the issue to the file of the AO for a fresh adjudication, in line with the decision taken by he AO in the preceding years(s). Needless to mention, adequate and reasonable opportunity shall be given to the assessee, to present its case. Non giving credit of TDS - Held that:- The AO is legally bound to allow TDS to the assessee as per law. We, therefore, direct the AO to allow the undisputed and legally correct claim of TDS & on doing so, the AO shall allow the benefit of TDS, as claimed in the GOA.
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