https://www.taxtmi.com/highlights?id=70859 Income accrued in India - receipt from offshore sale of goods - rendering supporting services - fees for included services (FIS) - Article 12 of India-Ireland DTAA - A.O has not established that how the amount received by the assessee was related to rendering of any services by the assessee. A.O/DRP have not controverted the facts established from the invoices on sale of equipments as discussed supra in this order. - AT en-us Wed, 12 Jul 2023 12:34:59 +0530 Wed, 12 Jul 2023 12:34:59 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=70859 Income accrued in India - receipt from offshore sale of goods - rendering supporting services - fees for included services (FIS) - Article 12 of India-Ireland DTAA - A.O has not established that how the amount received by the assessee was related to rendering of any services by the assessee. A.O/DRP have not controverted the facts established from the invoices on sale of equipments as discussed supra in this order. - AT Highlights Income Tax Wed, 12 Jul 2023 12:34:59 +0530 https://www.taxtmi.com/highlights?id=70859