https://www.taxtmi.com/caselaws?id=279890 The Tribunal dismissed the Revenue's appeals and allowed the Cross Objections of the assessee. It held that the reopening of the assessment under section 147 of the Income-tax Act was invalid as the reasons were not based on new tangible material. Additionally, it ruled that the Management Service Fees received by the assessee were not taxable in India under the Double Taxation Avoidance Agreement due to the services not meeting the "make available" criterion for technical services. en-us Tue, 05 Jun 2018 00:00:00 +0530 Wed, 10 Apr 2019 06:12:14 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=279890 The Tribunal dismissed the Revenue's appeals and allowed the Cross Objections of the assessee. It held that the reopening of the assessment under section 147 of the Income-tax Act was invalid as the reasons were not based on new tangible material. Additionally, it ruled that the Management Service Fees received by the assessee were not taxable in India under the Double Taxation Avoidance Agreement due to the services not meeting the "make available" criterion for technical services. Case-Laws Income Tax Tue, 05 Jun 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=279890