https://www.taxtmi.com/caselaws?id=444754 Reassessment was treated as unsustainable because the material facts had not changed and the Tribunal's earlier view in the assessee's own case already covered the controversy; the reassessment proceedings and consequential assessment were quashed. On the substantive issue, the Tribunal applied its prior ruling and held that the assessee was entitled to Article 8 protection under the India-Singapore DTAA, so the document and vessel handling charges were not taxable in India. The appeal therefore succeeded on both the jurisdictional and treaty-taxation grounds, and the stay request became infructuous. en-us Thu, 19 Oct 2023 00:00:00 +0530 Sat, 21 Oct 2023 07:02:21 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=444754 Reassessment was treated as unsustainable because the material facts had not changed and the Tribunal's earlier view in the assessee's own case already covered the controversy; the reassessment proceedings and consequential assessment were quashed. On the substantive issue, the Tribunal applied its prior ruling and held that the assessee was entitled to Article 8 protection under the India-Singapore DTAA, so the document and vessel handling charges were not taxable in India. The appeal therefore succeeded on both the jurisdictional and treaty-taxation grounds, and the stay request became infructuous. Case-Laws Income Tax Thu, 19 Oct 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=444754