Tribunal held that identical issue had come up before Tribunal in assessee’s own case in assessment years 2009-10 to 2013-14 and it remanded issue to Assessing Officer for fresh consideration. Accordingly the order was remanded to Assessing Officer for consideration afresh. (AY. 2017-18)
Kennametal Inc. v. ACIT (2022) 194 ITD 617 (Bang.)(Trib.)
S. 9(1)(vi) : Income deemed to accrue or arise in India-Royalty-Information technology support services to its group entities-Matter remanded-DTAA-India-USA. [S. 9(1)(vii), Art. 12]