https://www.taxtmi.com/caselaws?id=418325 The Tribunal confirmed the disallowance made by the Assessing Officer under section 40(a)(i) of the Income-tax Act, 1961, as the payment made by the Indian company to its Netherlands-based holding company was characterized as 'Royalty.' The Tribunal held that the payment for IT Support Services constituted 'Royalty' under both domestic law and the Double Taxation Avoidance Agreement (DTAA) between India and Netherlands. Consequently, the Tribunal upheld the disallowance, emphasizing the necessity of proper tax deduction on payments classified as 'Royalty' under international tax agreements. en-us Wed, 09 Feb 2022 00:00:00 +0530 Fri, 02 Dec 2022 10:21:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=418325 The Tribunal confirmed the disallowance made by the Assessing Officer under section 40(a)(i) of the Income-tax Act, 1961, as the payment made by the Indian company to its Netherlands-based holding company was characterized as 'Royalty.' The Tribunal held that the payment for IT Support Services constituted 'Royalty' under both domestic law and the Double Taxation Avoidance Agreement (DTAA) between India and Netherlands. Consequently, the Tribunal upheld the disallowance, emphasizing the necessity of proper tax deduction on payments classified as 'Royalty' under international tax agreements. Case-Laws Income Tax Wed, 09 Feb 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=418325