https://www.taxtmi.com/caselaws?id=444235 The Tribunal condoned the delay in filing appeals due to a genuine cause and admitted them for adjudication. The engineering package fee and on-site man-day charges were held not taxable as Fees for Technical Services under the India-Portugal DTAA exceptions. The assessee benefitted from the Most Favoured Nation clause, as the receipts did not qualify as FTS. Receipts under the expired Technical Collaboration Agreement were not taxable. ITA Nos. 9483/Del/2019 and 9484/Del/2019 were allowed, while ITA No. 3410/Del/2016 was dismissed. en-us Wed, 06 Sep 2023 00:00:00 +0530 Thu, 12 Oct 2023 09:03:54 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=444235 The Tribunal condoned the delay in filing appeals due to a genuine cause and admitted them for adjudication. The engineering package fee and on-site man-day charges were held not taxable as Fees for Technical Services under the India-Portugal DTAA exceptions. The assessee benefitted from the Most Favoured Nation clause, as the receipts did not qualify as FTS. Receipts under the expired Technical Collaboration Agreement were not taxable. ITA Nos. 9483/Del/2019 and 9484/Del/2019 were allowed, while ITA No. 3410/Del/2016 was dismissed. Case-Laws Income Tax Wed, 06 Sep 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=444235