https://www.taxtmi.com/caselaws?id=251579 The Tax Tribunal partly allowed the appeal by a non-resident company incorporated in Thailand, directing the Assessing Officer to re-examine whether the services provided under the Master Service Agreement qualify as royalty under the India-Thailand DTAA. The Tribunal emphasized the need to differentiate between advisory services and imparting know-how for tax purposes under international tax treaties. Penalty proceedings under section 271(1)(c) were dismissed as premature in light of the Tribunal's findings. en-us Wed, 06 Aug 2014 00:00:00 +0530 Wed, 15 Apr 2015 10:48:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=251579 The Tax Tribunal partly allowed the appeal by a non-resident company incorporated in Thailand, directing the Assessing Officer to re-examine whether the services provided under the Master Service Agreement qualify as royalty under the India-Thailand DTAA. The Tribunal emphasized the need to differentiate between advisory services and imparting know-how for tax purposes under international tax treaties. Penalty proceedings under section 271(1)(c) were dismissed as premature in light of the Tribunal's findings. Case-Laws Income Tax Wed, 06 Aug 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=251579