https://www.taxtmi.com/caselaws?id=293037 The Delhi HC remanded the case to ITAT to assess the applicability of the Indo-US DTAA concerning fees for technical services. The ITAT concluded that the services did not meet the criteria for "making available" technical knowledge under the DTAA. Hence, the fees were not taxable in India, and the disallowance under section 40(a)(ia) of the Act was unwarranted. The AO was directed to delete the disallowance, allowing the assessee's appeal. en-us Thu, 24 May 2018 00:00:00 +0530 Wed, 13 Nov 2024 11:51:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=293037 The Delhi HC remanded the case to ITAT to assess the applicability of the Indo-US DTAA concerning fees for technical services. The ITAT concluded that the services did not meet the criteria for "making available" technical knowledge under the DTAA. Hence, the fees were not taxable in India, and the disallowance under section 40(a)(ia) of the Act was unwarranted. The AO was directed to delete the disallowance, allowing the assessee's appeal. Case-Laws Income Tax Thu, 24 May 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=293037