https://www.taxtmi.com/caselaws?id=442475 Payments for employee training in soft skills, leadership and general management did not constitute fees for technical services under the applicable treaty framework because they did not make available technical knowledge, experience, skill, know-how or processes. No tax deduction obligation arose, so the expenditure disallowance was deleted. Additional legal grounds were admissible where relevant facts were already on record and consideration was necessary to determine the correct tax liability. As the factual matrix for those grounds required examination, they were restored to the Assessing Officer for fresh adjudication, allowing the taxpayer to substantiate the claim and requiring consideration of relevant precedents. en-us Wed, 07 Jun 2023 00:00:00 +0530 Sat, 02 Sep 2023 07:51:19 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=442475 Payments for employee training in soft skills, leadership and general management did not constitute fees for technical services under the applicable treaty framework because they did not make available technical knowledge, experience, skill, know-how or processes. No tax deduction obligation arose, so the expenditure disallowance was deleted. Additional legal grounds were admissible where relevant facts were already on record and consideration was necessary to determine the correct tax liability. As the factual matrix for those grounds required examination, they were restored to the Assessing Officer for fresh adjudication, allowing the taxpayer to substantiate the claim and requiring consideration of relevant precedents. Case-Laws Income Tax Wed, 07 Jun 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=442475