https://www.taxtmi.com/caselaws?id=762399 Delhi HC upheld ITAT's decision deleting addition under Section 40(a)(i) for non-deduction of TDS on payments to US entity. Assessee paid US manufacturer for remote technical support services to Indian customers. ITAT found services were call center support without technology transfer element, not constituting fees for technical services under Section 9(vii) or DTAA Article 12. HC rejected Revenue's contention that US entity provided knowledge/technology to assessee, noting factual findings were not challenged as perverse. Decision favored assessee. en-us Wed, 13 Nov 2024 00:00:00 +0530 Sat, 30 Nov 2024 08:41:55 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=762399 Delhi HC upheld ITAT's decision deleting addition under Section 40(a)(i) for non-deduction of TDS on payments to US entity. Assessee paid US manufacturer for remote technical support services to Indian customers. ITAT found services were call center support without technology transfer element, not constituting fees for technical services under Section 9(vii) or DTAA Article 12. HC rejected Revenue's contention that US entity provided knowledge/technology to assessee, noting factual findings were not challenged as perverse. Decision favored assessee. Case-Laws Income Tax Wed, 13 Nov 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=762399