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Territorial rendering requirement excludes China-based management and consultancy services from fees for technical services under the India-China DTAA...
Section 270A penalty for under-reporting was not leviable under the provision where a health and education cess deduction claim, made in reliance on judicial decisions, was withdrawn during assessment after a retrospective amendment. Coordinate Tribunal decisions on the identical issue supported the conclusion that withdrawal of the claim did not justify penalty. The penalty was consequently deleted.
Section 270A penalty for under-reporting was not leviable under the provision where a health and education cess deduction claim, made in reliance on judicial decisions, was withdrawn during assessment after a retrospective amendment. Coordinate Tribunal decisions on the identical issue supported the conclusion that withdrawal of the claim did not justify penalty. The penalty was consequently deleted.
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