https://www.taxtmi.com/caselaws?id=433460 The Tribunal allowed the appeals for statistical purposes, directing the AO to reassess issues based on its findings. It concluded that TSIS and Management Service Fees are not taxable as royalty or FTS, and instructed the AO to delete related additions. The Tribunal also mandated corrections for TDS credit and interest levies under sections 234A and 234B, remanding these issues for verification and de novo adjudication. The decision emphasized the non-taxability of certain fees under the India-France DTAA, allowing the assessee to benefit from the restrictive definition of FTS under the India-USA DTAA. en-us Fri, 23 Dec 2022 00:00:00 +0530 Mon, 10 Jun 2024 17:30:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=433460 The Tribunal allowed the appeals for statistical purposes, directing the AO to reassess issues based on its findings. It concluded that TSIS and Management Service Fees are not taxable as royalty or FTS, and instructed the AO to delete related additions. The Tribunal also mandated corrections for TDS credit and interest levies under sections 234A and 234B, remanding these issues for verification and de novo adjudication. The decision emphasized the non-taxability of certain fees under the India-France DTAA, allowing the assessee to benefit from the restrictive definition of FTS under the India-USA DTAA. Case-Laws Income Tax Fri, 23 Dec 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=433460