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The Income Tax Appellate Tribunal held that the receipt from supply planning services was not taxable as fees for technical services or royalty under the India-United Kingdom tax treaty. The coordinate bench had previously decided the identical issue, ruling that such receipts were not chargeable to tax. The Tribunal, following the coordinate bench's decision in the assessee's own case for the last 5 years, upheld the order of the Commissioner of Income Tax (Appeals) and dismissed the grounds of appeal raised by the Assessing Officer. The decision was rendered in favor of the assessee.
The Income Tax Appellate Tribunal held that the receipt from supply planning services was not taxable as fees for technical services or royalty under the India-United Kingdom tax treaty. The coordinate bench had previously decided the identical issue, ruling that such receipts were not chargeable to tax. The Tribunal, following the coordinate bench's decision in the assessee's own case for the last 5 years, upheld the order of the Commissioner of Income Tax (Appeals) and dismissed the grounds of appeal raised by the Assessing Officer. The decision was rendered in favor of the assessee.
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