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Madras HC remanded matter back to AO as assessee had raised issue related to DTAA first time before court

September 26, 2020[2020] 119 taxmann.com 386 (Madras)
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INTERNATIONAL TAXATION : Where issue relating to section 90 of Income-tax Act read with Double Taxation Avoidance Agreement between India and USA had not been raised before Assessing Officer or before Commissioner (Appeals) or before Tribunal, but for first time assessee had raised issue before this Court and said issue had also been raised in substantial questions of law, occasion to deal with said issue in this tax case Appeal did not arise

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