https://www.taxtmi.com/highlights?id=103122 Reversal of opening accrued and unbilled revenue already recognised and taxed in an earlier year was allowable where an indistinguishable coordinate-bench ruling applied; the related disallowance was deleted. Professional fees paid to non-residents were not established as royalty under the applicable tax treaty. Consequently, non-deduction of tax under section 195 did not justify disallowance, and deletion of that adjustment was sustained. The taxpayer's appeal succeeded, while the Revenue's appeal failed. en-us Thu, 27 Aug 2026 08:28:54 +0530 Thu, 27 Aug 2026 08:28:54 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=103122 Reversal of opening accrued and unbilled revenue already recognised and taxed in an earlier year was allowable where an indistinguishable coordinate-bench ruling applied; the related disallowance was deleted. Professional fees paid to non-residents were not established as royalty under the applicable tax treaty. Consequently, non-deduction of tax under section 195 did not justify disallowance, and deletion of that adjustment was sustained. The taxpayer's appeal succeeded, while the Revenue's appeal failed. Highlights Income Tax Thu, 27 Aug 2026 08:28:54 +0530 https://www.taxtmi.com/highlights?id=103122