https://www.taxtmi.com/caselaws?id=202804 Section 80HHC restricts the export deduction to Indian companies and persons resident in India. A non-resident cannot rely on the India-Singapore DTAA non-discrimination clause to obtain that deduction where the treaty excludes obligations to grant personal allowances, reliefs, reductions and deductions to residents of the other contracting state. An assessment allowing the deduction without examining the taxpayer's non-resident status and relevant treaty provisions is erroneous and prejudicial to Revenue interests, permitting revision under section 263. An advance ruling remains binding on the applicant, preventing challenge to an issue already determined by that ruling. en-us Fri, 22 May 2009 00:00:00 +0530 Thu, 06 Jun 2013 12:26:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=202804 Section 80HHC restricts the export deduction to Indian companies and persons resident in India. A non-resident cannot rely on the India-Singapore DTAA non-discrimination clause to obtain that deduction where the treaty excludes obligations to grant personal allowances, reliefs, reductions and deductions to residents of the other contracting state. An assessment allowing the deduction without examining the taxpayer's non-resident status and relevant treaty provisions is erroneous and prejudicial to Revenue interests, permitting revision under section 263. An advance ruling remains binding on the applicant, preventing challenge to an issue already determined by that ruling. Case-Laws Income Tax Fri, 22 May 2009 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=202804