https://www.taxtmi.com/caselaws?id=777185 ITAT DELHI - AT held that payments to non-resident foreign attorneys/law firms were fees for professional services under s.194J and not Fees for Technical Services under s.9(1)(vii); the AO erred in treating them as FTS and taxing them under s.9. Noting the distinct statutory definitions and that s.40(a)(i)'s Explanation defines only FTS, the Tribunal applied lex specialis and concluded such professional fees do not accrue or arise in India for tax under the Act. Appeal allowed. en-us Wed, 20 Aug 2025 00:00:00 +0530 Sat, 23 Aug 2025 13:28:49 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=777185 ITAT DELHI - AT held that payments to non-resident foreign attorneys/law firms were fees for professional services under s.194J and not Fees for Technical Services under s.9(1)(vii); the AO erred in treating them as FTS and taxing them under s.9. Noting the distinct statutory definitions and that s.40(a)(i)'s Explanation defines only FTS, the Tribunal applied lex specialis and concluded such professional fees do not accrue or arise in India for tax under the Act. Appeal allowed. Case-Laws Income Tax Wed, 20 Aug 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=777185