https://www.taxtmi.com/caselaws?id=371921 In the absence of a permanent establishment and with no change in facts, treaty taxation prevailed over the higher domestic rate under sections 115A and 44DA, so the royalty and interest receipts were taxable at 10 per cent under the Indo-German treaty. The Tribunal relied on its earlier orders in the assessee's own case and noted that the Revenue's pending High Court appeal did not alter the position for the year under consideration. The reimbursement of expenses and related TDS credit issues were treated as requiring verification, so they were remitted to the Assessing Officer for fresh adjudication after examination of invoices and due opportunity to the assessee. en-us Tue, 11 Dec 2018 00:00:00 +0530 Fri, 14 Dec 2018 07:21:05 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=371921 In the absence of a permanent establishment and with no change in facts, treaty taxation prevailed over the higher domestic rate under sections 115A and 44DA, so the royalty and interest receipts were taxable at 10 per cent under the Indo-German treaty. The Tribunal relied on its earlier orders in the assessee's own case and noted that the Revenue's pending High Court appeal did not alter the position for the year under consideration. The reimbursement of expenses and related TDS credit issues were treated as requiring verification, so they were remitted to the Assessing Officer for fresh adjudication after examination of invoices and due opportunity to the assessee. Case-Laws Income Tax Tue, 11 Dec 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=371921