https://www.taxtmi.com/caselaws?id=434779 The tribunal allowed the appeal, ruling that the amount received for providing business support services by the non-resident corporate entity from the Netherlands should not be considered as fees for technical services (FTS) under the India-Netherlands Double Taxation Avoidance Agreement. The services were deemed managerial in nature, not meeting the FTS criteria under the DTAA. As the "make available" condition was not satisfied, the payment was not taxable in India, leading to the deletion of the tax addition imposed by the Assessing Officer for the assessment year 2014-15. en-us Tue, 31 Jan 2023 00:00:00 +0530 Fri, 03 Mar 2023 22:18:25 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=434779 The tribunal allowed the appeal, ruling that the amount received for providing business support services by the non-resident corporate entity from the Netherlands should not be considered as fees for technical services (FTS) under the India-Netherlands Double Taxation Avoidance Agreement. The services were deemed managerial in nature, not meeting the FTS criteria under the DTAA. As the "make available" condition was not satisfied, the payment was not taxable in India, leading to the deletion of the tax addition imposed by the Assessing Officer for the assessment year 2014-15. Case-Laws Income Tax Tue, 31 Jan 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=434779