https://www.taxtmi.com/caselaws?id=780627 Management fee or processing fee received in connection with an ECB loan was treated as loan-related consideration rather than fee for technical services. Applying its earlier view, the ITAT held that charges such as management, commitment and documentation fees, when closely linked to the loan facility, fall within the domestic law definition of interest. On that basis, the receipt was not taxable as fee for technical services under section 9(1)(vii) and was covered by treaty protection under Article 11(3)(b) of the India-Germany DTAA. The addition was deleted. en-us Thu, 30 Oct 2025 00:00:00 +0530 Mon, 03 Nov 2025 08:13:54 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=780627 Management fee or processing fee received in connection with an ECB loan was treated as loan-related consideration rather than fee for technical services. Applying its earlier view, the ITAT held that charges such as management, commitment and documentation fees, when closely linked to the loan facility, fall within the domestic law definition of interest. On that basis, the receipt was not taxable as fee for technical services under section 9(1)(vii) and was covered by treaty protection under Article 11(3)(b) of the India-Germany DTAA. The addition was deleted. Case-Laws Income Tax Thu, 30 Oct 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=780627