https://www.taxtmi.com/caselaws?id=62758 The Tribunal ruled in favor of the appellant, holding that the appellant's income from CSC was not taxable in India under Article 8 of the DTAA. The Tribunal also allowed deductions under Section 57(iii) for expenses related to the receipts from CSC, resulting in no taxable income. The principle of consistency regarding tax treatment across different assessment years was not considered persuasive by the Tribunal. As a result, the appeals were allowed, and the additions made by the Assessing Officer were deleted. en-us Mon, 31 Mar 2008 00:00:00 +0530 Sat, 15 Jun 2013 12:54:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=62758 The Tribunal ruled in favor of the appellant, holding that the appellant's income from CSC was not taxable in India under Article 8 of the DTAA. The Tribunal also allowed deductions under Section 57(iii) for expenses related to the receipts from CSC, resulting in no taxable income. The principle of consistency regarding tax treatment across different assessment years was not considered persuasive by the Tribunal. As a result, the appeals were allowed, and the additions made by the Assessing Officer were deleted. Case-Laws Income Tax Mon, 31 Mar 2008 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=62758