https://www.taxtmi.com/highlights?id=89074 HC affirmed ITAT's ruling regarding income tax treatment of technical service fees from Indian customers. The court found no taxable technical service fees under India-USA DTAA or Section 9(1)(vii). Corporate allocation charges were deemed non-taxable as the assessee did not render direct services, transfer skills, or send employees to India. The court concluded that the ITAT's fact-specific findings were sound and no substantial legal question existed, effectively upholding the lower tribunal's assessment of non-taxability of the disputed income streams. en-us Wed, 04 Jun 2025 08:40:40 +0530 Wed, 04 Jun 2025 08:40:41 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=89074 HC affirmed ITAT's ruling regarding income tax treatment of technical service fees from Indian customers. The court found no taxable technical service fees under India-USA DTAA or Section 9(1)(vii). Corporate allocation charges were deemed non-taxable as the assessee did not render direct services, transfer skills, or send employees to India. The court concluded that the ITAT's fact-specific findings were sound and no substantial legal question existed, effectively upholding the lower tribunal's assessment of non-taxability of the disputed income streams. Highlights Income Tax Wed, 04 Jun 2025 08:40:40 +0530 https://www.taxtmi.com/highlights?id=89074