Electronic WhatsApp evidence without authentication or independent corroboration cannot sustain an unexplained-investment addition based on third-part...
Mutual current-account transactions excluded from deemed dividend treatment where no fresh borrowing arose; unsupported unsecured-loan addition also f...
ITAT determined that remittances for data management charges do not constitute taxable technical services under section 9(1)(vii)(b). The non-resident entity lacks permanent establishment in India. Referencing precedent, the tribunal held that technical services are only taxable when the recipient cannot independently apply the technical knowledge without the service provider's aid. The tribunal directed the Assessing Officer to grant appropriate TDS credit and recalculate refund figures in accordance with legal provisions, allowing the grounds for statistical purposes.
ITAT determined that remittances for data management charges do not constitute taxable technical services under section 9(1)(vii)(b). The non-resident entity lacks permanent establishment in India. Referencing precedent, the tribunal held that technical services are only taxable when the recipient cannot independently apply the technical knowledge without the service provider's aid. The tribunal directed the Assessing Officer to grant appropriate TDS credit and recalculate refund figures in accordance with legal provisions, allowing the grounds for statistical purposes.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
