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2020 (12) TMI 1157 - AT - Income TaxIncome accrued in India - Management services fee claim - royalty receipt - eligibility for benefits of Indo-Netherland DTAA - assessee claimed the same as managerial services, as it did not make available any technical knowledge, experience, skill, know-how or process - HELD THAT:- We fallow the judicial precedence and ratio of the decisions the Hon’ble Tribunal [2017 (11) TMI 1912 - ITAT MUMBAI] payments received by the assessee as per the service agreement dated 01.04.2004 does not come into the nature of royalty as defined Article 12(4) India Netherlands Tax Treaty. Accordingly, we set aside the order passed by the Assessing officer and allow the grounds of appeal of the assessee.
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