https://www.taxtmi.com/caselaws?id=432414 Treaty limitation provisions apply only when their stated conditions are cumulatively met; because the assessee's Singapore income was taxed on an accrual basis, Article 24 of the India-Singapore DTAA did not deny treaty benefits. Licence fee receipts from SET were treated as royalty because the agreement conveyed a bundle of live and recorded exploitation rights, but the absence of a contractual split required apportionment, so only 25% was taxable in India. Sponsorship receipts from LG, Hero Honda and Hutch were promotional arrangements and not royalty for use of commercial equipment. Reopening was valid on tangible material where the return had only been processed under section 143(1). Interest under section 234B was not leviable. en-us Wed, 14 Dec 2022 00:00:00 +0530 Thu, 05 Jan 2023 08:26:10 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=432414 Treaty limitation provisions apply only when their stated conditions are cumulatively met; because the assessee's Singapore income was taxed on an accrual basis, Article 24 of the India-Singapore DTAA did not deny treaty benefits. Licence fee receipts from SET were treated as royalty because the agreement conveyed a bundle of live and recorded exploitation rights, but the absence of a contractual split required apportionment, so only 25% was taxable in India. Sponsorship receipts from LG, Hero Honda and Hutch were promotional arrangements and not royalty for use of commercial equipment. Reopening was valid on tangible material where the return had only been processed under section 143(1). Interest under section 234B was not leviable. Case-Laws Income Tax Wed, 14 Dec 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=432414