https://www.taxtmi.com/caselaws?id=441354 The Tribunal allowed the appeal, condoning the delay in filing and setting aside the additions made by the AO and CIT(A). It directed the AO to verify the taxation of the disputed income in subsequent years, emphasizing the precedence of DTAA provisions over domestic law, particularly regarding the taxation of royalty income on a receipt basis. The Tribunal ruled in favor of the assessee on the taxation of royalty income and addressed concerns of potential double taxation, while penalty and interest issues were deemed consequential and not separately adjudicated. en-us Thu, 03 Aug 2023 00:00:00 +0530 Tue, 08 Aug 2023 10:48:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=441354 The Tribunal allowed the appeal, condoning the delay in filing and setting aside the additions made by the AO and CIT(A). It directed the AO to verify the taxation of the disputed income in subsequent years, emphasizing the precedence of DTAA provisions over domestic law, particularly regarding the taxation of royalty income on a receipt basis. The Tribunal ruled in favor of the assessee on the taxation of royalty income and addressed concerns of potential double taxation, while penalty and interest issues were deemed consequential and not separately adjudicated. Case-Laws Income Tax Thu, 03 Aug 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=441354