https://www.taxtmi.com/caselaws?id=312389 Sales and marketing commission earned for promoting products, coordinating with foreign customers and following up collections was not taxable as fee for technical services under the Act because the activities were neither technical, managerial nor consultancy in nature and did not involve making available any technical knowledge, skill or know-how. The same income also did not fall within fees for included services under Article 12 of the India-USA DTAA, as the functions were comparable to export marketing and agency services. The taxability addition was deleted. en-us Fri, 23 Sep 2022 00:00:00 +0530 Thu, 15 Feb 2024 05:29:39 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=312389 Sales and marketing commission earned for promoting products, coordinating with foreign customers and following up collections was not taxable as fee for technical services under the Act because the activities were neither technical, managerial nor consultancy in nature and did not involve making available any technical knowledge, skill or know-how. The same income also did not fall within fees for included services under Article 12 of the India-USA DTAA, as the functions were comparable to export marketing and agency services. The taxability addition was deleted. Case-Laws Income Tax Fri, 23 Sep 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=312389