https://www.taxtmi.com/caselaws?id=440070 An alleged conflict of interest based on an advocate's separate administrative-side engagement for RTI matters did not disqualify counsel from appearing before the ITAT, and the departmental representative lacked locus to seek such disqualification; the preliminary objection was rejected. On the merits, guarantee fee received by a Korean tax resident from Indian subsidiaries was treated as other income under the India-Korea tax treaty and held taxable only in Korea under Article 23, so the Indian addition was deleted. Because the section 263 revision for the earlier year depended on the same taxability view, it could not stand and was quashed. en-us Wed, 05 Jul 2023 00:00:00 +0530 Mon, 17 Mar 2025 10:21:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=440070 An alleged conflict of interest based on an advocate's separate administrative-side engagement for RTI matters did not disqualify counsel from appearing before the ITAT, and the departmental representative lacked locus to seek such disqualification; the preliminary objection was rejected. On the merits, guarantee fee received by a Korean tax resident from Indian subsidiaries was treated as other income under the India-Korea tax treaty and held taxable only in Korea under Article 23, so the Indian addition was deleted. Because the section 263 revision for the earlier year depended on the same taxability view, it could not stand and was quashed. Case-Laws Income Tax Wed, 05 Jul 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=440070