https://www.taxtmi.com/caselaws?id=776924 Penalty under Section 270-A of the Income-tax Act was held not leviable where the taxability of secondment-related reimbursements and IT support service receipts was genuinely debatable. The receipts were contested as either fee for technical services under the Act or fees for included services under Article 12 of the India-US DTAA, and conflicting judicial views, including a jurisdictional ruling favouring the assessee, supported a bona fide belief of non-taxability. In that setting, the Tribunal treated the issue as vexed with two possible views and the penalty could not be sustained. en-us Fri, 01 Aug 2025 00:00:00 +0530 Thu, 21 Aug 2025 08:35:52 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=776924 Penalty under Section 270-A of the Income-tax Act was held not leviable where the taxability of secondment-related reimbursements and IT support service receipts was genuinely debatable. The receipts were contested as either fee for technical services under the Act or fees for included services under Article 12 of the India-US DTAA, and conflicting judicial views, including a jurisdictional ruling favouring the assessee, supported a bona fide belief of non-taxability. In that setting, the Tribunal treated the issue as vexed with two possible views and the penalty could not be sustained. Case-Laws Income Tax Fri, 01 Aug 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=776924