https://www.taxtmi.com/caselaws?id=468628 Where the material facts were identical to an earlier year, additions on reinsurance premium and retrocession premium based on alleged business connection or permanent establishment were deleted. The Tribunal also held that support service receipts were not taxable as fees for technical services because the revenue had not shown that technical knowledge, skill or experience was made available under the treaty. The TDS credit claim was remanded for factual verification by the Assessing Officer, while interest under section 234D was treated as mandatory and consequential to be computed under the statute. en-us Thu, 25 Sep 2025 00:00:00 +0530 Thu, 14 May 2026 19:45:05 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=468628 Where the material facts were identical to an earlier year, additions on reinsurance premium and retrocession premium based on alleged business connection or permanent establishment were deleted. The Tribunal also held that support service receipts were not taxable as fees for technical services because the revenue had not shown that technical knowledge, skill or experience was made available under the treaty. The TDS credit claim was remanded for factual verification by the Assessing Officer, while interest under section 234D was treated as mandatory and consequential to be computed under the statute. Case-Laws Income Tax Thu, 25 Sep 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=468628