https://www.taxtmi.com/caselaws?id=443805 The Tribunal upheld the CIT(A)'s decision in the case, ruling that the payments received by the assessee for Juniper Services do not qualify as Royalty or Fees for Technical Services (FTS) under the India-Netherlands Double Taxation Avoidance Agreement (DTAA). The Tribunal found that the services provided by the assessee did not involve the transfer of technical knowledge to the recipient, and therefore, the income was not taxable in India as Royalty or FTS. Additionally, the Tribunal dismissed the revenue's appeals for multiple assessment years, affirming that the payments in question were not subject to taxation under the DTAA. en-us Tue, 26 Sep 2023 00:00:00 +0530 Sat, 30 Sep 2023 12:49:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=443805 The Tribunal upheld the CIT(A)'s decision in the case, ruling that the payments received by the assessee for Juniper Services do not qualify as Royalty or Fees for Technical Services (FTS) under the India-Netherlands Double Taxation Avoidance Agreement (DTAA). The Tribunal found that the services provided by the assessee did not involve the transfer of technical knowledge to the recipient, and therefore, the income was not taxable in India as Royalty or FTS. Additionally, the Tribunal dismissed the revenue's appeals for multiple assessment years, affirming that the payments in question were not subject to taxation under the DTAA. Case-Laws Income Tax Tue, 26 Sep 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=443805