https://www.taxtmi.com/caselaws?id=437733 The Tribunal upheld the assessee's plea regarding the taxability of Management Service Fees, ruling that they did not qualify as "Royalty" under the India-Netherlands DTAA. Consequently, the addition of these fees was deleted, and other related issues were deemed academic. The Tribunal directed the AO to verify and grant TDS credit, remanded the issue of interest for fresh adjudication, and dismissed the initiation of penalty proceedings as premature. The appeals for the assessment years 2018-19 and 2019-20 were partly allowed for statistical purposes based on previous rulings in the assessee's favor. en-us Fri, 31 Mar 2023 00:00:00 +0530 Fri, 12 May 2023 11:59:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=437733 The Tribunal upheld the assessee's plea regarding the taxability of Management Service Fees, ruling that they did not qualify as "Royalty" under the India-Netherlands DTAA. Consequently, the addition of these fees was deleted, and other related issues were deemed academic. The Tribunal directed the AO to verify and grant TDS credit, remanded the issue of interest for fresh adjudication, and dismissed the initiation of penalty proceedings as premature. The appeals for the assessment years 2018-19 and 2019-20 were partly allowed for statistical purposes based on previous rulings in the assessee's favor. Case-Laws Income Tax Fri, 31 Mar 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=437733