https://www.taxtmi.com/caselaws?id=187765 The appellate tribunal upheld the CIT(A)'s decision that 50% of the payment for Value Added Services (VAS) constituted royalty/fees for technical services, while the remaining 50% was classified as business receipts. The tribunal dismissed the Revenue's appeal, affirming the taxability of the payment under the Double Taxation Agreement based on the nature of services provided by DTC and the absence of a Permanent Establishment in India. en-us Wed, 17 Feb 2010 00:00:00 +0530 Sat, 05 Nov 2016 14:59:03 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=187765 The appellate tribunal upheld the CIT(A)'s decision that 50% of the payment for Value Added Services (VAS) constituted royalty/fees for technical services, while the remaining 50% was classified as business receipts. The tribunal dismissed the Revenue's appeal, affirming the taxability of the payment under the Double Taxation Agreement based on the nature of services provided by DTC and the absence of a Permanent Establishment in India. Case-Laws Income Tax Wed, 17 Feb 2010 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=187765