https://www.taxtmi.com/caselaws?id=55650 The Tribunal held that the initial grant of Double Taxation Avoidance (DTA) relief to non-resident ships did not constitute a mistake rectifiable under section 154. It emphasized the distinction between procedural and substantive rights, stating that procedural irregularities did not invalidate the substantive right to relief under DTA agreements with Germany and Greece. The Tribunal criticized the tax authority's actions as arbitrary and reinstated the DTA reliefs, deeming the withdrawal orders as bad in law and without jurisdiction. As a result, all appeals were allowed, and the DTA reliefs were reinstated. en-us Tue, 26 Feb 1991 00:00:00 +0530 Mon, 29 Nov 2010 12:11:33 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=55650 The Tribunal held that the initial grant of Double Taxation Avoidance (DTA) relief to non-resident ships did not constitute a mistake rectifiable under section 154. It emphasized the distinction between procedural and substantive rights, stating that procedural irregularities did not invalidate the substantive right to relief under DTA agreements with Germany and Greece. The Tribunal criticized the tax authority's actions as arbitrary and reinstated the DTA reliefs, deeming the withdrawal orders as bad in law and without jurisdiction. As a result, all appeals were allowed, and the DTA reliefs were reinstated. Case-Laws Income Tax Tue, 26 Feb 1991 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=55650