No remand order as CIT(A) had analyzed all clauses of India-UK DTAA to hold that sums couldn’t be ta

IT/ILT : Where in order to determine taxability of payment made to a UK based company for supplying aircraft components to an Indian company, Tribunal remanded matter back to examine provisions of article 13 of India - UK DTAA, in view of fact that article 13(3)(a) would not apply to assessee's case, Commissioner (Appeals) was justified in examining matter from angle of article 13(3)(b) of DTAA only and holding that payment in question was not taxable in India as 'royalty'