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of The HC upheld the ITAT's decision rejecting the penalty under section 270A on the assessee, an Australian tax resident company receiving payments from an Indian entity for IT support and salary reimbursements. While the receipts were potentially taxable as fees for technical services under section 9(1)(vii) or fees for included services under the India-US DTAA, the existence of conflicting judicial opinions rendered the tax liability debatable. The assessee's bona fide belief in non-taxability and acceptance of the Vivad Se Vishwas Scheme to settle the dispute further supported the absence of penalty. The court found no infirmity in the ITAT's conclusion that the question involved was a vexed one, precluding penalty imposition. Consequently, no substantial question of law arose warranting interference, affirming the assessee's position and the non-levy of penalty under section 270A.
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