https://www.taxtmi.com/caselaws?id=169865 The ITAT Chennai dismissed both the Revenue's appeal and the assessee's cross objection, upholding the Commissioner of Income Tax (Appeals) decisions. The disallowance under section 40(a)(i) for carrier payments without TDS deduction was deemed unjustified as the services did not qualify as technical under the DTAA. Additionally, the addition of income accrued but not offered to tax was rejected, emphasizing that income only accrues upon service provision, not upon receipt of advance payments. The judgment stressed the importance of assessing service nature and income timing for tax purposes. en-us Thu, 27 Feb 2014 00:00:00 +0530 Fri, 27 Jun 2014 18:21:46 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=169865 The ITAT Chennai dismissed both the Revenue's appeal and the assessee's cross objection, upholding the Commissioner of Income Tax (Appeals) decisions. The disallowance under section 40(a)(i) for carrier payments without TDS deduction was deemed unjustified as the services did not qualify as technical under the DTAA. Additionally, the addition of income accrued but not offered to tax was rejected, emphasizing that income only accrues upon service provision, not upon receipt of advance payments. The judgment stressed the importance of assessing service nature and income timing for tax purposes. Case-Laws Income Tax Thu, 27 Feb 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=169865