TMI Blog2015 (8) TMI 457X X X X Extracts X X X X X X X X Extracts X X X X ..... the applicant will be entitled to take the benefit of Portugal Treaty also - Held that:- We examined the application threadbare. The three questions which have been asked do not pertain to income on royalty or the income generated on account of the earned interest. There is no statement found in the whole application that the applicant does not have an income from royalty or from interest. In tha ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... or the applicant Kanv Bali, Deputy Commissioner and Ms. Anusha Khurana, Additional Commissioner for the Department. RULING 1. Heard Shri Piyush Kaushik on behalf of the applicant and Shri Kanv Bali and Ms. Anusha Khurana on behalf of the Revenue. We have perused the application. The applicant raises a question about the taxability of the income generated by fees for technical servic ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... n fact, the applicant had earned some income on account of royalty and as also interest income. It is then pointed out that the tax has been charged on the royalty as well as the interest income. According to the Department, therefore, in not claiming any question pertaining to the income on royalty and the interest income, the applicant had as a matter of fact tried to avoid the payment of Income ..... X X X X Extracts X X X X X X X X Extracts X X X X
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