https://www.taxtmi.com/caselaws?id=402358 The Tribunal partly allowed the assessee's appeal, determining that the management service fees did not qualify as Royalty under Article 12(4) of the India-Netherlands DTAA. Consequently, the Tribunal set aside the A.O.'s order, aligning with prior rulings that the services did not impart technical knowledge. The stay applications were dismissed as infructuous. en-us Thu, 24 Dec 2020 00:00:00 +0530 Mon, 04 Nov 2024 12:00:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=402358 The Tribunal partly allowed the assessee's appeal, determining that the management service fees did not qualify as Royalty under Article 12(4) of the India-Netherlands DTAA. Consequently, the Tribunal set aside the A.O.'s order, aligning with prior rulings that the services did not impart technical knowledge. The stay applications were dismissed as infructuous. Case-Laws Income Tax Thu, 24 Dec 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=402358