https://www.taxtmi.com/caselaws?id=462820 The Delhi HC rejected the contention that a UK tax resident non-filer was barred from maintaining an appeal for not filing returns under Section 139 or responding to notices under Section 148 of the Income Tax Act, 1961. The court held that Section 260A provisions are unambiguous - appeals lie against every Tribunal order if substantial questions of law are involved. The court admitted the appeal on two questions: whether the appellant was taxable on receipts of INR 3,31,98,980 under the Act or India-UK DTAA, and whether the Tribunal erred in re-characterizing business receipts as fees for technical services under Section 9(1)(vii) and Article 13(4)(c) of the DTAA. The matter was listed for hearing on 13.05.2025. en-us Thu, 17 Apr 2025 00:00:00 +0530 Thu, 17 Jul 2025 18:58:41 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=462820 The Delhi HC rejected the contention that a UK tax resident non-filer was barred from maintaining an appeal for not filing returns under Section 139 or responding to notices under Section 148 of the Income Tax Act, 1961. The court held that Section 260A provisions are unambiguous - appeals lie against every Tribunal order if substantial questions of law are involved. The court admitted the appeal on two questions: whether the appellant was taxable on receipts of INR 3,31,98,980 under the Act or India-UK DTAA, and whether the Tribunal erred in re-characterizing business receipts as fees for technical services under Section 9(1)(vii) and Article 13(4)(c) of the DTAA. The matter was listed for hearing on 13.05.2025. Case-Laws Income Tax Thu, 17 Apr 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=462820