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2012 (10) TMI 405 - AT - Income TaxTax on receipts from Dubai, UAE companies - u/s. 44D r.w.s. 115A OR u/s. 44BB - Held that:- Undoubtedly Hon'ble Jurisdictional High Court has held that income in this case is chargeable u/s. 44D read with section 115A but the issue as to whether the assessee was entitled to relief under Article 22 of the DTAA between India and UAE has not been looked into. Also this issue was also earlier remitted by the Tribunal to the file of the AO and AO has not considered it the matter needs to be referred back to the Assessing Officer to consider the same - in favour of assessee for statistical purposes.
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