https://www.taxtmi.com/caselaws?id=768359 ITAT Delhi allowed the appeal and remanded the case to the AO for fresh adjudication. The assessee claimed a lower interest rate of 5% under Section 115A read with Section 194LC, but CPC taxed at 10% under the India-Netherlands Tax Treaty. The CIT(A) rejected the claim on technical grounds rather than deciding on merits, including issues about filing a revised return and AAR application. ITAT held that appellate authorities can entertain new grounds citing Goetze India Ltd SC precedent, and directed the AO to decide the matter afresh on merits within three opportunities. en-us Wed, 26 Mar 2025 00:00:00 +0530 Sat, 05 Apr 2025 08:23:35 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=768359 ITAT Delhi allowed the appeal and remanded the case to the AO for fresh adjudication. The assessee claimed a lower interest rate of 5% under Section 115A read with Section 194LC, but CPC taxed at 10% under the India-Netherlands Tax Treaty. The CIT(A) rejected the claim on technical grounds rather than deciding on merits, including issues about filing a revised return and AAR application. ITAT held that appellate authorities can entertain new grounds citing Goetze India Ltd SC precedent, and directed the AO to decide the matter afresh on merits within three opportunities. Case-Laws Income Tax Wed, 26 Mar 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=768359