https://www.taxtmi.com/caselaws?id=59606 The Tribunal considered whether its earlier order contained a mistake apparent from the record for treating Article 7 of the India-Mauritius DTAA as inapplicable and for not examining the assessee's liability under that article. The material controversy was whether, on the assumed applicability of Article 7, the assessee had a permanent establishment in India and whether the income could be assessed on a gross basis under Section 44B. The earlier order was said to have overlooked the real issue and treated the discussion of Articles 4, 5 and 7 as academic. The miscellaneous application was allowed and the order was recalled for fresh consideration on taxability under Article 7 and the correct basis of computation. en-us Fri, 17 Jun 2005 00:00:00 +0530 Sat, 23 Jun 2012 10:41:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=59606 The Tribunal considered whether its earlier order contained a mistake apparent from the record for treating Article 7 of the India-Mauritius DTAA as inapplicable and for not examining the assessee's liability under that article. The material controversy was whether, on the assumed applicability of Article 7, the assessee had a permanent establishment in India and whether the income could be assessed on a gross basis under Section 44B. The earlier order was said to have overlooked the real issue and treated the discussion of Articles 4, 5 and 7 as academic. The miscellaneous application was allowed and the order was recalled for fresh consideration on taxability under Article 7 and the correct basis of computation. Case-Laws Income Tax Fri, 17 Jun 2005 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=59606