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    <title>2023 (1) TMI 1304 - ITAT PUNE</title>
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    <description>The ITAT Pune held that IT support service charges received by a Singapore entity for providing support and maintenance services to Indian customers were not taxable as Fees for Technical Services under the Income Tax Act and India-Singapore DTAA. The tribunal distinguished the current case from earlier years where the entire composite amount was treated as royalty, noting that post the SC decision in Engineering Analysis, the treatment changed. The tribunal concluded that IT support services income, even when viewed independently from software license income, was not chargeable to tax in India, deciding in favor of the assessee.</description>
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    <pubDate>Wed, 25 Jan 2023 00:00:00 +0530</pubDate>
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      <title>2023 (1) TMI 1304 - ITAT PUNE</title>
      <link>https://www.taxtmi.com/caselaws?id=310507</link>
      <description>The ITAT Pune held that IT support service charges received by a Singapore entity for providing support and maintenance services to Indian customers were not taxable as Fees for Technical Services under the Income Tax Act and India-Singapore DTAA. The tribunal distinguished the current case from earlier years where the entire composite amount was treated as royalty, noting that post the SC decision in Engineering Analysis, the treatment changed. The tribunal concluded that IT support services income, even when viewed independently from software license income, was not chargeable to tax in India, deciding in favor of the assessee.</description>
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