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ITAT set aside CIT(A)'s order regarding TDS obligations under s.195 for license fees paid to non-resident associated enterprise. The appellate authority failed to address crucial aspects: taxability of license fees under India-USA DTAA Article 12, and applicability of s.195 TDS requirements. CIT(A)'s decision was influenced by assessee's subsequent year tax compliance but lacked proper reasoning under s.250(6). Following established principle that statutory procedures must be strictly followed, ITAT found CIT(A)'s adjudication procedurally deficient. Both Revenue's appeal and assessee's cross-objection allowed for statistical purposes, with matter remanded for fresh consideration.
ITAT set aside CIT(A)'s order regarding TDS obligations under s.195 for license fees paid to non-resident associated enterprise. The appellate authority failed to address crucial aspects: taxability of license fees under India-USA DTAA Article 12, and applicability of s.195 TDS requirements. CIT(A)'s decision was influenced by assessee's subsequent year tax compliance but lacked proper reasoning under s.250(6). Following established principle that statutory procedures must be strictly followed, ITAT found CIT(A)'s adjudication procedurally deficient. Both Revenue's appeal and assessee's cross-objection allowed for statistical purposes, with matter remanded for fresh consideration.
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