https://www.taxtmi.com/caselaws?id=459527 A management fee received in connection with a loan transaction was treated as part of the interest stream under section 2(28A) because it was integrally linked to the loan and similar to accepted commitment and documentation fees. On that basis, it was not taxed separately as fees for technical services under section 9(1)(vii) or Article 12, and instead fell within the interest exemption under Article 11(3)(b) of the India-Germany treaty. The ITAT Delhi accordingly deleted the addition, holding that a payment closely connected with borrowed money cannot be isolated and taxed as technical services where the treaty protects interest. en-us Fri, 19 Jan 2024 00:00:00 +0530 Tue, 17 Dec 2024 18:57:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=459527 A management fee received in connection with a loan transaction was treated as part of the interest stream under section 2(28A) because it was integrally linked to the loan and similar to accepted commitment and documentation fees. On that basis, it was not taxed separately as fees for technical services under section 9(1)(vii) or Article 12, and instead fell within the interest exemption under Article 11(3)(b) of the India-Germany treaty. The ITAT Delhi accordingly deleted the addition, holding that a payment closely connected with borrowed money cannot be isolated and taxed as technical services where the treaty protects interest. Case-Laws Income Tax Fri, 19 Jan 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=459527