https://www.taxtmi.com/caselaws?id=463304 ITAT HYDERABAD - AT remanded the appeal to the file of CIT(A), holding that the assessee was not given sufficient opportunity and that CIT(A) must re-examine submissions regarding royalty and SAP maintenance payments and the effect of non-deduction of TDS. CIT(A) is directed to consider the interplay of DTAA and domestic law, the assessee's accounting treatment, and relevant binding decisions of the Tribunal, HC and SC, and to pass a fresh speaking order after affording the assessee a hearing. en-us Thu, 23 Nov 2023 00:00:00 +0530 Fri, 22 Aug 2025 20:06:51 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=463304 ITAT HYDERABAD - AT remanded the appeal to the file of CIT(A), holding that the assessee was not given sufficient opportunity and that CIT(A) must re-examine submissions regarding royalty and SAP maintenance payments and the effect of non-deduction of TDS. CIT(A) is directed to consider the interplay of DTAA and domestic law, the assessee's accounting treatment, and relevant binding decisions of the Tribunal, HC and SC, and to pass a fresh speaking order after affording the assessee a hearing. Case-Laws Income Tax Thu, 23 Nov 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=463304