https://www.taxtmi.com/caselaws?id=442475 Training payments for soft skills, leadership and general management were treated as not involving transfer of technology or making available technical knowledge, experience, skill, know-how or processes. On that basis, the service was said to fall outside fees for technical services under the treaty framework, so no tax deduction obligation arose and the section 40(a)(i) disallowance was deleted. The note also states that additional legal grounds may be admitted where the relevant facts are already on record; here, those grounds were admitted and the matter was restored to the Assessing Officer for fresh consideration with supporting material and precedents to be examined. 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 Training payments for soft skills, leadership and general management were treated as not involving transfer of technology or making available technical knowledge, experience, skill, know-how or processes. On that basis, the service was said to fall outside fees for technical services under the treaty framework, so no tax deduction obligation arose and the section 40(a)(i) disallowance was deleted. The note also states that additional legal grounds may be admitted where the relevant facts are already on record; here, those grounds were admitted and the matter was restored to the Assessing Officer for fresh consideration with supporting material and precedents to be examined. Case-Laws Income Tax Wed, 07 Jun 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=442475