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Income taxable in India - Treating the remittance as fees for technical services - supervision installation and commissioning services - CBDT Circular No. 3/2022 is not applicable to the present appeal, therefore, assessee is entitled to claim the benefit of the restricted definition under India-Portugal DTAA. Since, the assessee have been found not to have made available any technical knowledge experience or skill or knowhow, therefore, the impugned services received by the assessee cannot be taxed under the provision. - AT
Income taxable in India - Treating the remittance as fees for technical services - supervision installation and commissioning services - CBDT Circular No. 3/2022 is not applicable to the present appeal, therefore, assessee is entitled to claim the benefit of the restricted definition under India-Portugal DTAA. Since, the assessee have been found not to have made available any technical knowledge experience or skill or knowhow, therefore, the impugned services received by the assessee cannot be taxed under the provision. - AT
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