https://www.taxtmi.com/caselaws?id=441354 Delay in filing the appeal was condoned on the ground of reasonable cause, as the appeal had first been filed before the wrong forum and withdrawn after the jurisdictional position was clarified. On the substantive tax issue, royalty income under the India-Switzerland DTAA was treated as taxable on receipt basis rather than on mere accrual, because the assessee followed the cash system and the treaty was applied as the more beneficial provision over the domestic rule. The balance addition was therefore deleted, and the royalty adjustment was held unsustainable. 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 Delay in filing the appeal was condoned on the ground of reasonable cause, as the appeal had first been filed before the wrong forum and withdrawn after the jurisdictional position was clarified. On the substantive tax issue, royalty income under the India-Switzerland DTAA was treated as taxable on receipt basis rather than on mere accrual, because the assessee followed the cash system and the treaty was applied as the more beneficial provision over the domestic rule. The balance addition was therefore deleted, and the royalty adjustment was held unsustainable. Case-Laws Income Tax Thu, 03 Aug 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=441354