https://www.taxtmi.com/caselaws?id=399777 The Tribunal allowed the appeal, directing the AO to apply Explanation 7 to Section 9(1)(i) of the Income-tax Act, 1961, retrospectively, thereby deleting the addition of Rs. 36,33,15,969/- for the assessment year 2015-16. The Tribunal emphasized that Explanations 6 and 7 should be read in conjunction with Explanation 5, which was retrospective, to fully comprehend the legislative intent and ensure clarity in tax provisions. The decision underscored the importance of territorial nexus for taxability and provided relief to the appellant by recognizing the retrospective applicability of Explanation 7. en-us Thu, 15 Oct 2020 00:00:00 +0530 Tue, 05 Nov 2024 12:11:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=399777 The Tribunal allowed the appeal, directing the AO to apply Explanation 7 to Section 9(1)(i) of the Income-tax Act, 1961, retrospectively, thereby deleting the addition of Rs. 36,33,15,969/- for the assessment year 2015-16. The Tribunal emphasized that Explanations 6 and 7 should be read in conjunction with Explanation 5, which was retrospective, to fully comprehend the legislative intent and ensure clarity in tax provisions. The decision underscored the importance of territorial nexus for taxability and provided relief to the appellant by recognizing the retrospective applicability of Explanation 7. Case-Laws Income Tax Thu, 15 Oct 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=399777