This is premium content. Please become a Premium member. If you are already a member, login here to access the full content.
No Penalty u/s 271(1)(c) if two legal interpretations were possible and Assessee acted in bonafide manner
Case Law Details
- Case Name
- M/s Inspectorate Singapore Pte. Ltd. Vs ADIT (ITAT Delhi)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2010-11
- Courts
- All ITAT, ITAT Delhi
Upgrade to Basic or Premium to download.
Already Upgraded? Log in.
M/s Inspectorate Singapore Pte. Ltd. Vs ADIT (ITAT Delhi)
Assessee was under the belief that due to the ‘make available’ Clause in Article 12 (4) (b) of India Singapore DTAA, the consideration paid by the Indian customers to assessee cannot be regarded as ‘fees for technical services’ and further since there was no transfer of technology involved in the services extended by assessee, the consideration for such services could not be taxed under Article 12(4)(b) of the DTAA. Assessee relied upon various decisions of Jurisdictional High Court as well as Authority of Adv...
