https://www.taxtmi.com/caselaws?id=772945 A treaty-based claim for special-rate taxation of foreign income, supported by Form 67 filed before processing, was not examined on merits by the first appellate authority, which instead directed the assessee to seek rectification. As the claim had been raised in the return and the dispute required substantive consideration, the matter was restored for fresh adjudication in accordance with law with an opportunity of hearing. The result was remand to the first appellate authority for reconsideration of the treaty benefit claim, without a final determination on the tax treatment. en-us Fri, 13 Jun 2025 00:00:00 +0530 Mon, 16 Jun 2025 08:38:59 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=772945 A treaty-based claim for special-rate taxation of foreign income, supported by Form 67 filed before processing, was not examined on merits by the first appellate authority, which instead directed the assessee to seek rectification. As the claim had been raised in the return and the dispute required substantive consideration, the matter was restored for fresh adjudication in accordance with law with an opportunity of hearing. The result was remand to the first appellate authority for reconsideration of the treaty benefit claim, without a final determination on the tax treatment. Case-Laws Income Tax Fri, 13 Jun 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=772945