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HC allowed the petitioner's application under Section 197, ruling that cross-cost charges from associated enterprises do not constitute technical services or royalties under India-UK DTAA. The court found no transfer of technical knowledge, rights, or software copyrights, thereby rejecting the Assessing Officer's taxation claim. The HC directed the AO to issue a 'nil' withholding tax certificate, emphasizing that the services did not satisfy the conditions for Fees for Technical Services (FTS) or royalty provisions.
HC allowed the petitioner's application under Section 197, ruling that cross-cost charges from associated enterprises do not constitute technical services or royalties under India-UK DTAA. The court found no transfer of technical knowledge, rights, or software copyrights, thereby rejecting the Assessing Officer's taxation claim. The HC directed the AO to issue a 'nil' withholding tax certificate, emphasizing that the services did not satisfy the conditions for Fees for Technical Services (FTS) or royalty provisions.
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