https://www.taxtmi.com/caselaws?id=774989 The Delhi HC quashed a reassessment order passed under Section 147 where the AO had treated CRM receipts as Fees for Technical Services under the India-Singapore DTAA. The court held that the AO lacked jurisdiction to continue parallel assessment proceedings after the original assessment for AY 2018-19 was already completed. The DRP had noted that ITAT's decision deleting CRM additions had attained finality. The Revenue's appeal against this ITAT order was dismissed by the Delhi HC, which had earlier ruled in favor of the assessee in a similar case regarding CRM services not constituting royalty under the India-Singapore DTAA. Despite being informed of these adverse decisions, the AO proceeded with the impugned assessment. The HC found the assessment order unsustainable as it resulted from proceedings initiated without jurisdiction, and the issues were conclusively settled in the assessee's favor through prior judicial precedent. en-us Mon, 07 Jul 2025 00:00:00 +0530 Thu, 17 Jul 2025 08:19:12 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=774989 The Delhi HC quashed a reassessment order passed under Section 147 where the AO had treated CRM receipts as Fees for Technical Services under the India-Singapore DTAA. The court held that the AO lacked jurisdiction to continue parallel assessment proceedings after the original assessment for AY 2018-19 was already completed. The DRP had noted that ITAT's decision deleting CRM additions had attained finality. The Revenue's appeal against this ITAT order was dismissed by the Delhi HC, which had earlier ruled in favor of the assessee in a similar case regarding CRM services not constituting royalty under the India-Singapore DTAA. Despite being informed of these adverse decisions, the AO proceeded with the impugned assessment. The HC found the assessment order unsustainable as it resulted from proceedings initiated without jurisdiction, and the issues were conclusively settled in the assessee's favor through prior judicial precedent. Case-Laws Income Tax Mon, 07 Jul 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=774989