https://www.taxtmi.com/caselaws?id=385732 The Tribunal held that payments for software licenses and IT support services were not taxable as royalty under the DTAA. Training charges to entities in different categories of countries were found taxable or non-taxable based on FTS clauses. Design expenses to entities in various countries were not taxable due to DTAA provisions. Repairs and maintenance payments were taxable to entities in certain countries. Grossing up of payments under section 195A was deemed unwarranted. Section 206AA did not override DTAA provisions. The appeals of the assessee were partly allowed, emphasizing adherence to DTAA provisions and international tax principles. en-us Mon, 09 Sep 2019 00:00:00 +0530 Thu, 12 Sep 2019 09:53:53 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=385732 The Tribunal held that payments for software licenses and IT support services were not taxable as royalty under the DTAA. Training charges to entities in different categories of countries were found taxable or non-taxable based on FTS clauses. Design expenses to entities in various countries were not taxable due to DTAA provisions. Repairs and maintenance payments were taxable to entities in certain countries. Grossing up of payments under section 195A was deemed unwarranted. Section 206AA did not override DTAA provisions. The appeals of the assessee were partly allowed, emphasizing adherence to DTAA provisions and international tax principles. Case-Laws Income Tax Mon, 09 Sep 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=385732