https://www.taxtmi.com/caselaws?id=291084 The Tribunal partly allowed the appeals for both assessment years, directing the AO to delete the additions related to 'fees for technical services' for installation services and product inspection charges. The issue of 'Royalty' for CAD/CAM software was remitted back to the AO for reassessment due to insufficient details provided by the assessee. The Tribunal stressed the significance of the 'make available' test under the DTAA and the necessity for a thorough evaluation of software modifications and terms of use. en-us Mon, 16 May 2016 00:00:00 +0530 Wed, 28 Oct 2020 09:02:18 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=291084 The Tribunal partly allowed the appeals for both assessment years, directing the AO to delete the additions related to 'fees for technical services' for installation services and product inspection charges. The issue of 'Royalty' for CAD/CAM software was remitted back to the AO for reassessment due to insufficient details provided by the assessee. The Tribunal stressed the significance of the 'make available' test under the DTAA and the necessity for a thorough evaluation of software modifications and terms of use. Case-Laws Income Tax Mon, 16 May 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=291084