https://www.taxtmi.com/caselaws?id=441180 Income received for services rendered to an Indian company was held not chargeable to tax under Article 12 of the India-USA DTAA, and a mistaken reporting under the wrong head in the return did not by itself create tax liability. The Tribunal's view that rectification under section 154 could not be denied merely because no revised return had been filed was upheld, in light of the principle that taxpayers should receive relief clearly due to them. The revenue's challenge failed because no substantial question of law arose. en-us Tue, 25 Jul 2023 00:00:00 +0530 Wed, 07 Feb 2024 15:10:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=441180 Income received for services rendered to an Indian company was held not chargeable to tax under Article 12 of the India-USA DTAA, and a mistaken reporting under the wrong head in the return did not by itself create tax liability. The Tribunal's view that rectification under section 154 could not be denied merely because no revised return had been filed was upheld, in light of the principle that taxpayers should receive relief clearly due to them. The revenue's challenge failed because no substantial question of law arose. Case-Laws Income Tax Tue, 25 Jul 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=441180