https://www.taxtmi.com/caselaws?id=336491 Borrowed service charges were analysed under Article 12 of the relevant DTAA and treated as neither royalty nor fees for included services, with the Tribunal relying on earlier decisions in the assessee's own group cases and a mutual agreement procedure resolution. The Revenue's objection that the MAP resolution was confined to a particular year was rejected because the factual matrix was materially similar across the assessment years. On that basis, the Assessing Officer was found unjustified in taxing the receipt as fees for technical services, and the additions were deleted. en-us Fri, 21 Oct 2016 00:00:00 +0530 Thu, 22 Dec 2016 14:45:07 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=336491 Borrowed service charges were analysed under Article 12 of the relevant DTAA and treated as neither royalty nor fees for included services, with the Tribunal relying on earlier decisions in the assessee's own group cases and a mutual agreement procedure resolution. The Revenue's objection that the MAP resolution was confined to a particular year was rejected because the factual matrix was materially similar across the assessment years. On that basis, the Assessing Officer was found unjustified in taxing the receipt as fees for technical services, and the additions were deleted. Case-Laws Income Tax Fri, 21 Oct 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=336491