https://www.taxtmi.com/caselaws?id=776580 Penalty under section 270-A of the Income-tax Act was held not leviable where the taxability of receipts for seconded employees and IT support services was debatable and more than one view was possible. The receipts were disputed as either fee for technical services under the Act or fees for included services under the treaty, and prior judicial decisions had supported the assessee's position. On that basis, the assessee's non-taxability claim was treated as a bona fide belief, so the statutory ingredients for penalty were not satisfied. en-us Thu, 31 Jul 2025 00:00:00 +0530 Wed, 13 Aug 2025 07:27:30 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=776580 Penalty under section 270-A of the Income-tax Act was held not leviable where the taxability of receipts for seconded employees and IT support services was debatable and more than one view was possible. The receipts were disputed as either fee for technical services under the Act or fees for included services under the treaty, and prior judicial decisions had supported the assessee's position. On that basis, the assessee's non-taxability claim was treated as a bona fide belief, so the statutory ingredients for penalty were not satisfied. Case-Laws Income Tax Thu, 31 Jul 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=776580