https://www.taxtmi.com/caselaws?id=311270 Receipts from software subscription and related professional and training services were not taxable as fee for technical services under the Act or the India-Netherlands tax treaty because the arrangement did not transfer technology or underlying intellectual property and did not satisfy the treaty's "make available" requirement. TDS credit was left to factual verification, with eligible credit to be granted on due examination. The challenge to initiation of penalty proceedings under section 274 read with section 270A was rejected as premature at the assessment stage. en-us Tue, 29 Aug 2023 00:00:00 +0530 Sat, 16 Dec 2023 10:01:13 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=311270 Receipts from software subscription and related professional and training services were not taxable as fee for technical services under the Act or the India-Netherlands tax treaty because the arrangement did not transfer technology or underlying intellectual property and did not satisfy the treaty's "make available" requirement. TDS credit was left to factual verification, with eligible credit to be granted on due examination. The challenge to initiation of penalty proceedings under section 274 read with section 270A was rejected as premature at the assessment stage. Case-Laws Income Tax Tue, 29 Aug 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=311270