https://www.taxtmi.com/caselaws?id=378223 Bona fide pursuit of rectification under section 154, followed by prompt recourse to appeal, constituted sufficient cause for condonation under section 249(3), so refusal to condone delay was unsustainable. On treaty taxation, royalty and interest taxable under the India-UAE DTAA at capped treaty rates could not bear surcharge or education cess over and above those limits, because surcharge was within the treaty's tax definition and education cess was treated as an additional surcharge. The coordinate bench view on the same treaty language was followed, and the taxpayer obtained relief on both issues. en-us Fri, 29 Mar 2019 00:00:00 +0530 Wed, 10 Apr 2019 11:42:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=378223 Bona fide pursuit of rectification under section 154, followed by prompt recourse to appeal, constituted sufficient cause for condonation under section 249(3), so refusal to condone delay was unsustainable. On treaty taxation, royalty and interest taxable under the India-UAE DTAA at capped treaty rates could not bear surcharge or education cess over and above those limits, because surcharge was within the treaty's tax definition and education cess was treated as an additional surcharge. The coordinate bench view on the same treaty language was followed, and the taxpayer obtained relief on both issues. Case-Laws Income Tax Fri, 29 Mar 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=378223