https://www.taxtmi.com/caselaws?id=762306 ITAT Mumbai held that management service fees charged by foreign entity to Indian subsidiary without mark-up constitute cost reimbursements and do not fall within scope of royalty under Article 12(4) of India-Netherlands DTAA. The tribunal consistently ruled across multiple assessment years that such services without technical knowledge transfer are not taxable in India. Additionally, ITAT directed AO to grant appropriate TDS credit of Rs. 3,89,05,708 after verification, as amount appeared in Form 26AS but credit was denied by assessing officer. en-us Wed, 27 Mar 2024 00:00:00 +0530 Thu, 28 Nov 2024 12:04:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=762306 ITAT Mumbai held that management service fees charged by foreign entity to Indian subsidiary without mark-up constitute cost reimbursements and do not fall within scope of royalty under Article 12(4) of India-Netherlands DTAA. The tribunal consistently ruled across multiple assessment years that such services without technical knowledge transfer are not taxable in India. Additionally, ITAT directed AO to grant appropriate TDS credit of Rs. 3,89,05,708 after verification, as amount appeared in Form 26AS but credit was denied by assessing officer. Case-Laws Income Tax Wed, 27 Mar 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=762306