https://www.taxtmi.com/caselaws?id=300876 The Tribunal allowed the appeals for Assessment Years 2011-12 and 2012-13, ruling that payments under the Training and Computer Systems Agreement were not 'fees for technical services' or 'royalty' under the India-Netherlands tax treaty. It was held that training services provided were not technical, and access to reservation facilities did not constitute royalty. The Tribunal also clarified that the payments were business profits, not taxable in India due to the absence of a permanent establishment. Additionally, the Assessing Officer was directed not to include surcharge and education cess in the tax rate. en-us Fri, 09 Aug 2019 00:00:00 +0530 Tue, 01 Mar 2022 18:19:48 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=300876 The Tribunal allowed the appeals for Assessment Years 2011-12 and 2012-13, ruling that payments under the Training and Computer Systems Agreement were not 'fees for technical services' or 'royalty' under the India-Netherlands tax treaty. It was held that training services provided were not technical, and access to reservation facilities did not constitute royalty. The Tribunal also clarified that the payments were business profits, not taxable in India due to the absence of a permanent establishment. Additionally, the Assessing Officer was directed not to include surcharge and education cess in the tax rate. Case-Laws Income Tax Fri, 09 Aug 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=300876