https://www.taxtmi.com/caselaws?id=59713 The Tribunal partially allowed the Revenue's appeal and the assessee's cross-objection. It held that the CIT(A) erred in admitting additional evidence without allowing the AO to examine it, thus admitting the Revenue's ground. The Tribunal denied the assessee the benefit of Article 8 of the DTAA, as the assessee was not engaged in the transportation of goods as required. It upheld the application of Article 24, limiting Article 8 benefits due to non-remittance of income to Singapore. The Tribunal remitted the case to the AO for further examination under Article 7 regarding the assessee's potential PE in India. It upheld the CIT(A)'s decision that interest under Section 234B could not be charged. en-us Thu, 26 Jun 2008 00:00:00 +0530 Sun, 10 Dec 2023 18:33:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=59713 The Tribunal partially allowed the Revenue's appeal and the assessee's cross-objection. It held that the CIT(A) erred in admitting additional evidence without allowing the AO to examine it, thus admitting the Revenue's ground. The Tribunal denied the assessee the benefit of Article 8 of the DTAA, as the assessee was not engaged in the transportation of goods as required. It upheld the application of Article 24, limiting Article 8 benefits due to non-remittance of income to Singapore. The Tribunal remitted the case to the AO for further examination under Article 7 regarding the assessee's potential PE in India. It upheld the CIT(A)'s decision that interest under Section 234B could not be charged. Case-Laws Income Tax Thu, 26 Jun 2008 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=59713