https://www.taxtmi.com/caselaws?id=763116 ITAT Delhi held that receipts by foreign associated enterprise from Indian company for software, engineering and infrastructure services were not taxable in India. AO contended payments constituted fees for technical services under section 9(1)(vii) based on actual conduct rather than legal contracts. ITAT distinguished cases cited by Revenue, noting assessee rendered services to foreign customers outside India who utilized services in overseas businesses. Following Delhi HC precedent in International Management Group case involving similar facts, ITAT concluded services were for earning income from sources outside India, making receipts non-taxable under domestic law. Appeal decided in favor of assessee. en-us Wed, 30 Oct 2024 00:00:00 +0530 Thu, 12 Dec 2024 16:42:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=763116 ITAT Delhi held that receipts by foreign associated enterprise from Indian company for software, engineering and infrastructure services were not taxable in India. AO contended payments constituted fees for technical services under section 9(1)(vii) based on actual conduct rather than legal contracts. ITAT distinguished cases cited by Revenue, noting assessee rendered services to foreign customers outside India who utilized services in overseas businesses. Following Delhi HC precedent in International Management Group case involving similar facts, ITAT concluded services were for earning income from sources outside India, making receipts non-taxable under domestic law. Appeal decided in favor of assessee. Case-Laws Income Tax Wed, 30 Oct 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=763116