https://www.taxtmi.com/caselaws?id=292615 Consulting and engineering fee and common cost recharge receipts were directed to be reconsidered afresh by the Assessing Officer because the treatment of both items depended on the characterisation adopted in the assessee's earlier year. The Tribunal noted that the consulting and engineering receipts had already been offered to tax for the year under consideration, while the recharge receipts were disputed as not taxable under Article 13 of the India-UK DTAA. As the earlier Tribunal ruling had treated the consulting and engineering receipts as business profits and the recharge as ancillary to those services, the assessee was to be given an opportunity to establish identity of facts before de novo adjudication. en-us Wed, 13 Nov 2019 00:00:00 +0530 Wed, 13 Nov 2024 12:00:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=292615 Consulting and engineering fee and common cost recharge receipts were directed to be reconsidered afresh by the Assessing Officer because the treatment of both items depended on the characterisation adopted in the assessee's earlier year. The Tribunal noted that the consulting and engineering receipts had already been offered to tax for the year under consideration, while the recharge receipts were disputed as not taxable under Article 13 of the India-UK DTAA. As the earlier Tribunal ruling had treated the consulting and engineering receipts as business profits and the recharge as ancillary to those services, the assessee was to be given an opportunity to establish identity of facts before de novo adjudication. Case-Laws Income Tax Wed, 13 Nov 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=292615