https://www.taxtmi.com/caselaws?id=752389 Receipts from business application support, end-user services, shared infrastructure, network access, IT support and business consultancy were treated as fees for technical services under Article 12(3)(b) of the India-Sweden DTAA because the treaty definition was read broadly to cover managerial, technical or consultancy services, and the most favoured nation argument and consistency plea were rejected; the receipts were therefore taxable in the hands of the assessee. Levy of interest was remitted to the Assessing Officer for factual verification and fresh decision after hearing the assessee, and non-grant of TDS credit on interest under section 244A was similarly restored for verification and decision according to law. en-us Tue, 07 May 2024 00:00:00 +0530 Wed, 08 May 2024 18:56:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=752389 Receipts from business application support, end-user services, shared infrastructure, network access, IT support and business consultancy were treated as fees for technical services under Article 12(3)(b) of the India-Sweden DTAA because the treaty definition was read broadly to cover managerial, technical or consultancy services, and the most favoured nation argument and consistency plea were rejected; the receipts were therefore taxable in the hands of the assessee. Levy of interest was remitted to the Assessing Officer for factual verification and fresh decision after hearing the assessee, and non-grant of TDS credit on interest under section 244A was similarly restored for verification and decision according to law. Case-Laws Income Tax Tue, 07 May 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=752389