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2023 (3) TMI 1135 - AT - Income TaxIncome deemed to accrue or arise in India - receipts towards IT support services - 'Fees for Technical Services' ("FTS") as per India- Netherlands DTAA - whether be treated as fee for technical services under the Act as well as under the DTAA as has been done in earlier years - HELD THAT:- This Tribunal for A.Y.2017-18 in assessee’s own case had disposed of the appeal [2022 (8) TMI 1263 - ITAT MUMBAI] wherein by following its own order for A.Y.2016-17 [2020 (3) TMI 1417 - ITAT MUMBAI] held that the payment received for IT support services cannot be treated either as fee for technical services or as royalty both under the Act as well as under the DTAA.
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