https://www.taxtmi.com/caselaws?id=761900 The ITAT Bangalore held that the AO exceeded jurisdiction by reclassifying income as FTS instead of royalty during remand proceedings. The Tribunal had issued a limited remand to examine chargeability under the Engineering Analysis Centre of Excellence SC judgment regarding royalty provisions under section 9(1)(vi). The AO could not go beyond the specific remand directions to examine FTS applicability under section 9(1)(vii) without seeking modification of the remand order. The addition was deleted on technical grounds as the reclassification was outside the scope of the limited remand order. en-us Tue, 08 Oct 2024 00:00:00 +0530 Tue, 19 Nov 2024 11:54:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=761900 The ITAT Bangalore held that the AO exceeded jurisdiction by reclassifying income as FTS instead of royalty during remand proceedings. The Tribunal had issued a limited remand to examine chargeability under the Engineering Analysis Centre of Excellence SC judgment regarding royalty provisions under section 9(1)(vi). The AO could not go beyond the specific remand directions to examine FTS applicability under section 9(1)(vii) without seeking modification of the remand order. The addition was deleted on technical grounds as the reclassification was outside the scope of the limited remand order. Case-Laws Income Tax Tue, 08 Oct 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=761900