https://www.taxtmi.com/caselaws?id=753153 ITAT Chennai held that sales commission received by a non-resident US company for liaising with customers and communicating requirements to an Indian entity does not constitute "fee for included services" under section 9(1) of the Income Tax Act. The assessee's role was limited to customer interaction and requirement communication, not service execution. The tribunal distinguished this from included services, noting the Indian entity was solely responsible for project execution. The addition was deleted and the assessee's appeal was allowed, treating the payment as sales commission not taxable in India. en-us Fri, 10 May 2024 00:00:00 +0530 Mon, 16 Dec 2024 15:05:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=753153 ITAT Chennai held that sales commission received by a non-resident US company for liaising with customers and communicating requirements to an Indian entity does not constitute "fee for included services" under section 9(1) of the Income Tax Act. The assessee's role was limited to customer interaction and requirement communication, not service execution. The tribunal distinguished this from included services, noting the Indian entity was solely responsible for project execution. The addition was deleted and the assessee's appeal was allowed, treating the payment as sales commission not taxable in India. Case-Laws Income Tax Fri, 10 May 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=753153