If DTAA is silent on a particular type of income, it will not automatically become business Income

ITAT CHENNAI DCIT v. TVS Electronics Ltd. IT Appeal NO. 811 (MDS.) of 2010 [ASSESSMENT YEAR 2005-06] MAY 25, 2012 ORDER Abraham P. George, Accountant Member – This is an appeal filed by the Revenue against order dated 18.3.2010 of Commissioner of Income Tax (Appeals)-III, Chennai, for the impugned assessment year, in which two core issues have been raised by it. First is on a deletion of an addition made by the A.O. on account of unexpired value of Annual Maintenance Contracts received by the assessee during the relevant previous year. Second issue is regarding deletion ...