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    <title>1994 (6) TMI 50 - ITAT MADRAS-C</title>
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    <description>A challenge to taxability on legal grounds can amount to a denial of liability to be assessed, so an appeal against an intimation under section 143(1) was maintainable. The appellate remedy was therefore available even though returns had been filed and returned income accepted. On merits, pension paid by the Government of the United Kingdom for services rendered was taxable only in that State under article 19(3) of the India-UK treaty, so it was not taxable in India. The assessments were set aside and any tax collected for the relevant years was directed to be refunded.</description>
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    <pubDate>Fri, 17 Jun 1994 00:00:00 +0530</pubDate>
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      <title>1994 (6) TMI 50 - ITAT MADRAS-C</title>
      <link>https://www.taxtmi.com/caselaws?id=70036</link>
      <description>A challenge to taxability on legal grounds can amount to a denial of liability to be assessed, so an appeal against an intimation under section 143(1) was maintainable. The appellate remedy was therefore available even though returns had been filed and returned income accepted. On merits, pension paid by the Government of the United Kingdom for services rendered was taxable only in that State under article 19(3) of the India-UK treaty, so it was not taxable in India. The assessments were set aside and any tax collected for the relevant years was directed to be refunded.</description>
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      <pubDate>Fri, 17 Jun 1994 00:00:00 +0530</pubDate>
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