https://www.taxtmi.com/caselaws?id=368449 An advance ruling remains binding only until a subsequent change in law or treaty terms alters the legal position, and a protocol forms part of the treaty and may modify its scope. On that basis, the taxability of fees for technical services and the applicability of section 44D and section 115A under the substituted India-Sweden DTAA required fresh examination in light of the later treaty framework, so the matter was remitted for de novo consideration. The allocation of common expenses and lease rentals also required re-examination because complete supporting material, including full final accounts of the associated enterprise, had not been furnished; the assessee was to be given an opportunity to produce proper evidence. en-us Wed, 04 Jul 2018 00:00:00 +0530 Tue, 09 Oct 2018 06:43:53 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=368449 An advance ruling remains binding only until a subsequent change in law or treaty terms alters the legal position, and a protocol forms part of the treaty and may modify its scope. On that basis, the taxability of fees for technical services and the applicability of section 44D and section 115A under the substituted India-Sweden DTAA required fresh examination in light of the later treaty framework, so the matter was remitted for de novo consideration. The allocation of common expenses and lease rentals also required re-examination because complete supporting material, including full final accounts of the associated enterprise, had not been furnished; the assessee was to be given an opportunity to produce proper evidence. Case-Laws Income Tax Wed, 04 Jul 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=368449