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AO's addition of "washout charges" as income was rejected. ITAT held that washout charges are business income, not speculative income. Even if speculative, it would be covered under Article 7 read with Article 5 of India-Singapore tax treaty as business income. Since the assessee had no PE in India as per Article 5, such business income is not taxable in India. ITAT ruled in assessee's favor.
AO's addition of "washout charges" as income was rejected. ITAT held that washout charges are business income, not speculative income. Even if speculative, it would be covered under Article 7 read with Article 5 of India-Singapore tax treaty as business income. Since the assessee had no PE in India as per Article 5, such business income is not taxable in India. ITAT ruled in assessee's favor.
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