No Penalty u/s 271(1)(c) if two legal interpretations were possible and Assessee acted in bonafide manner

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 vari

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