https://www.taxtmi.com/caselaws?id=304825 The Tribunal set aside the CIT(A)'s classification of commission income as Fee for Technical Services (FTS) under the India-Germany DTAA, directing the Assessing Officer to treat the income as neither royalty nor FTS. The Tribunal emphasized that the services provided were operational support services and did not involve substantial management functions required for classification as FTS. Additionally, the Tribunal instructed the AO to verify and allow the full credit of TDS claimed by the assessee. The appeals were allowed in part for statistical purposes, with one appeal fully allowed. en-us Tue, 23 Aug 2022 00:00:00 +0530 Wed, 13 Sep 2023 16:13:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=304825 The Tribunal set aside the CIT(A)'s classification of commission income as Fee for Technical Services (FTS) under the India-Germany DTAA, directing the Assessing Officer to treat the income as neither royalty nor FTS. The Tribunal emphasized that the services provided were operational support services and did not involve substantial management functions required for classification as FTS. Additionally, the Tribunal instructed the AO to verify and allow the full credit of TDS claimed by the assessee. The appeals were allowed in part for statistical purposes, with one appeal fully allowed. Case-Laws Income Tax Tue, 23 Aug 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=304825