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ITAT determined that receipts from simulator services to an Indian entity do not constitute Fees for Technical Services (FTS). The tribunal rejected Revenue's arguments regarding taxability under section 9(1)(vii), finding the services were standard flight simulator provisions rather than customized technical services. Relying on jurisdictional HC precedent, the tribunal held that providing standard operating mechanism simulators to Indian pilots in Ethiopia does not trigger tax liability. The Revenue's contentions regarding residential status and statutory amendments were dismissed. Consequently, the appellate tribunal ruled in favor of the assessee, negating the lower authorities' interpretation and holding that the impugned receipts are not taxable in India.
ITAT determined that receipts from simulator services to an Indian entity do not constitute Fees for Technical Services (FTS). The tribunal rejected Revenue's arguments regarding taxability under section 9(1)(vii), finding the services were standard flight simulator provisions rather than customized technical services. Relying on jurisdictional HC precedent, the tribunal held that providing standard operating mechanism simulators to Indian pilots in Ethiopia does not trigger tax liability. The Revenue's contentions regarding residential status and statutory amendments were dismissed. Consequently, the appellate tribunal ruled in favor of the assessee, negating the lower authorities' interpretation and holding that the impugned receipts are not taxable in India.
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