https://www.taxtmi.com/caselaws?id=762210 Arbitral award receipts arising from an offshore supply contract were characterised as business income rather than income from other sources because they represented compensation for non-payment of contractual dues and were inseparable from the underlying business transaction. In the absence of a permanent establishment in India, the principal amount was held not chargeable to tax in India. The interest component on delayed contractual compensation was also treated as part of the same business receipt and not as a separate taxable source, and the duplicated addition was directed to be deleted. As the substantive additions were removed, penalty proceedings under section 270A did not survive. en-us Thu, 14 Nov 2024 00:00:00 +0530 Wed, 27 Nov 2024 08:58:23 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=762210 Arbitral award receipts arising from an offshore supply contract were characterised as business income rather than income from other sources because they represented compensation for non-payment of contractual dues and were inseparable from the underlying business transaction. In the absence of a permanent establishment in India, the principal amount was held not chargeable to tax in India. The interest component on delayed contractual compensation was also treated as part of the same business receipt and not as a separate taxable source, and the duplicated addition was directed to be deleted. As the substantive additions were removed, penalty proceedings under section 270A did not survive. Case-Laws Income Tax Thu, 14 Nov 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=762210