Income accrued in India - Service desk provided by the assessee...

Income accrued in India - Service desk provided by the assessee to the employees of Tower Watson to monitor the IT related glitch - - services provided by the assessee is separate and it only collected the related cost to maintain the service desk. Therefore, it is a receipt which will fall under the Article 7 of the treaty. Hence, the addition proposed and sustained by the Ld.DRP are beyond the scope and accordingly Assessing Officer is directed to delete the same. - AT