ITAT: Sec.4 chargeability pre-condition for invoking Chapter-X; Deletes TP-adjustment towards hypothetical FCCD interest


Conclusion

Delhi ITAT dismisses Revenue’s appeal, upholds deletion of TP-adjustment on account of interest on FCCDs absent chargeability u/s. 4 r.w. Article 11(1) of India-Cyprus DTAA in ca...

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