https://www.taxtmi.com/caselaws?id=763903 ITAT Delhi ruled that income received by a foreign assessee from Indian customers for providing cloud-native machine data analytics solution does not qualify as Fees for Technical Services under Article 12(4) of the India-US DTAA. The assessee had submitted Tax Residency Certificate and offered the India-generated income for taxation in the resident country as business income, meeting legal requirements. The tribunal allowed grounds 1-6 of the appeal and directed the Assessing Officer to verify and allow TDS credit as per law, noting discrepancies between TDS granted and claimed amounts. en-us Fri, 27 Dec 2024 00:00:00 +0530 Tue, 31 Dec 2024 08:43:11 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=763903 ITAT Delhi ruled that income received by a foreign assessee from Indian customers for providing cloud-native machine data analytics solution does not qualify as Fees for Technical Services under Article 12(4) of the India-US DTAA. The assessee had submitted Tax Residency Certificate and offered the India-generated income for taxation in the resident country as business income, meeting legal requirements. The tribunal allowed grounds 1-6 of the appeal and directed the Assessing Officer to verify and allow TDS credit as per law, noting discrepancies between TDS granted and claimed amounts. Case-Laws Income Tax Fri, 27 Dec 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=763903