https://www.taxtmi.com/caselaws?id=389929 The Tribunal ruled in favor of the Assessee on the primary issues of the "Force of Attraction" rule, taxability of reimbursements, and levy of interest. The Assessee's revenues were taxed at 10% instead of 20% under the Double Taxation Avoidance Agreement between India and Germany. Reimbursements received without markup were not taxed as income. The Tribunal also held that interest under Sections 234A, 234B, and 234C was not chargeable. However, the reassessment proceedings under Section 147 for A.Y. 2002-03 and the penalty proceedings under Section 271(1)(c) were dismissed. The Tribunal partly allowed the appeals for A.Y. 2004-05 and 2005-06, ruling against the Assessee on the applicability of Section 44BBB. en-us Wed, 09 Oct 2019 00:00:00 +0530 Thu, 19 Dec 2019 11:28:10 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=389929 The Tribunal ruled in favor of the Assessee on the primary issues of the "Force of Attraction" rule, taxability of reimbursements, and levy of interest. The Assessee's revenues were taxed at 10% instead of 20% under the Double Taxation Avoidance Agreement between India and Germany. Reimbursements received without markup were not taxed as income. The Tribunal also held that interest under Sections 234A, 234B, and 234C was not chargeable. However, the reassessment proceedings under Section 147 for A.Y. 2002-03 and the penalty proceedings under Section 271(1)(c) were dismissed. The Tribunal partly allowed the appeals for A.Y. 2004-05 and 2005-06, ruling against the Assessee on the applicability of Section 44BBB. Case-Laws Income Tax Wed, 09 Oct 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=389929