https://www.taxtmi.com/highlights?id=84344 AO's addition of "washout charges" as income was rejected. ITAT held that washout charges are business income, not speculative income. Even if speculative, it would be covered under Article 7 read with Article 5 of India-Singapore tax treaty as business income. Since the assessee had no PE in India as per Article 5, such business income is not taxable in India. ITAT ruled in assessee's favor. en-us Fri, 27 Dec 2024 09:00:37 +0530 Fri, 27 Dec 2024 09:00:37 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=84344 AO's addition of "washout charges" as income was rejected. ITAT held that washout charges are business income, not speculative income. Even if speculative, it would be covered under Article 7 read with Article 5 of India-Singapore tax treaty as business income. Since the assessee had no PE in India as per Article 5, such business income is not taxable in India. ITAT ruled in assessee's favor. Highlights Income Tax Fri, 27 Dec 2024 09:00:37 +0530 https://www.taxtmi.com/highlights?id=84344