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ITAT held that foreign remittances characterized as "management/processing fees" are not taxable as fees for technical services (FTS) and therefore the addition treating them as FTS is deleted; the appeal ground challenging taxability is allowed following a co-ordinate bench precedent in the assessee's own case. With respect to levy of fee under s.234F, the Tribunal directed the AO to verify the assessee's contention that the return was filed in response to an s.148 notice and, if established, to take action in accordance with law regarding applicability of s.234F.
ITAT held that foreign remittances characterized as "management/processing fees" are not taxable as fees for technical services (FTS) and therefore the addition treating them as FTS is deleted; the appeal ground challenging taxability is allowed following a co-ordinate bench precedent in the assessee's own case. With respect to levy of fee under s.234F, the Tribunal directed the AO to verify the assessee's contention that the return was filed in response to an s.148 notice and, if established, to take action in accordance with law regarding applicability of s.234F.
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