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The ITAT allowed the appellant's appeal by holding that Infrastructure Data Center (IDC) charges and Management Service Fees received are not taxable as royalty under the India-Singapore DTAA. The Tribunal relied on a coordinate bench decision in the appellant's own case, which established that IDC and CRM Development Charges do not constitute taxable income in India. Consequently, the Assessing Officer's additions on account of IDC charges and Management Service Fees were directed to be deleted. Both grounds raised in the appellant's appeal were thus allowed, resulting in the reversal of the taxability determination and deletion of the impugned additions.
The ITAT allowed the appellant's appeal by holding that Infrastructure Data Center (IDC) charges and Management Service Fees received are not taxable as royalty under the India-Singapore DTAA. The Tribunal relied on a coordinate bench decision in the appellant's own case, which established that IDC and CRM Development Charges do not constitute taxable income in India. Consequently, the Assessing Officer's additions on account of IDC charges and Management Service Fees were directed to be deleted. Both grounds raised in the appellant's appeal were thus allowed, resulting in the reversal of the taxability determination and deletion of the impugned additions.
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