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Tribunal Allows Income Rectification u/s 154, Grants DTAA Benefits for Taxability Issue in India-USA Case.

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....Rectification of mistake u/s 154 - subject income being inadvertently shown under the wrong head - Taxability of income in India - The benefit of Article 121 of India-USA Double Taxation Avoidance Agreement [in short, “Indo-USA DTAA”] was available to the respondent/assessee. - Tribunal rightly allowed the claim of assessee - HC....

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Tribunal Allows Income Rectification u/s 154, Grants DTAA Benefits for Taxability Issue in India-USA Case.