https://www.taxtmi.com/caselaws?id=780255 ITAT held that support service fees received under the GFNA are not taxable in India: they do not constitute royalty or FTS under s.9(1)(vi) or Article 12 of the India-Netherlands DTAA, nor business profits under Article 7 because no PE existed in India. The tribunal relied on Revenue's consistent acceptance in preceding years that the services were commercial (not technical/managerial), were rendered from outside India, and did not "make available" technical knowledge or skills to the Indian entity. Revenue's grounds were dismissed. en-us Mon, 29 Sep 2025 00:00:00 +0530 Mon, 27 Oct 2025 09:17:14 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=780255 ITAT held that support service fees received under the GFNA are not taxable in India: they do not constitute royalty or FTS under s.9(1)(vi) or Article 12 of the India-Netherlands DTAA, nor business profits under Article 7 because no PE existed in India. The tribunal relied on Revenue's consistent acceptance in preceding years that the services were commercial (not technical/managerial), were rendered from outside India, and did not "make available" technical knowledge or skills to the Indian entity. Revenue's grounds were dismissed. Case-Laws Income Tax Mon, 29 Sep 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=780255