https://www.taxtmi.com/caselaws?id=312246 The ITAT ruled in favor of the assessee, determining that payments for data transmission services are neither "Royalty" nor "Fee for Technical Services" under the IT Act and DTAA, due to the absence of a Permanent Establishment. The Tribunal applied previous favorable High Court judgments, dismissing the revenue's appeal. Additionally, penalty proceedings under section 270A were deemed unjustified, as the matters had been settled in the assessee's favor. The Tribunal's decision reinforced the interpretation of the DTAA and IT Act, aligning with established legal precedents and effectively concluding the appeal in support of the assessee. en-us Thu, 25 Feb 2021 00:00:00 +0530 Fri, 19 Jul 2024 17:40:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=312246 The ITAT ruled in favor of the assessee, determining that payments for data transmission services are neither "Royalty" nor "Fee for Technical Services" under the IT Act and DTAA, due to the absence of a Permanent Establishment. The Tribunal applied previous favorable High Court judgments, dismissing the revenue's appeal. Additionally, penalty proceedings under section 270A were deemed unjustified, as the matters had been settled in the assessee's favor. The Tribunal's decision reinforced the interpretation of the DTAA and IT Act, aligning with established legal precedents and effectively concluding the appeal in support of the assessee. Case-Laws Income Tax Thu, 25 Feb 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=312246