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    <title>IT support and non-IT services not taxable as FTS/FIS under India-UK DTAA; TDS u/s 195 relief upheld</title>
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    <description>ITAT held in favour of the appellant that amounts received for rendering IT support and non-IT services are not taxable as Fee for Technical Services/Fee for Included Services under the Act or the India-UK DTAA for purposes of TDS u/s 195. The Tribunal affirmed the DRP&#039;s factual finding that &quot;IT support&quot; and &quot;IT development&quot; services were dissimilar and found no reliable evidence that technical knowledge, skill or know-how was made available to the associated enterprise in India or that the assessee enabled the AE to perform the services independently. Consequently the additions treating receipts as FTS/FIS were deleted and both grounds of appeal were allowed.</description>
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    <pubDate>Sat, 08 Nov 2025 08:30:03 +0530</pubDate>
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      <title>IT support and non-IT services not taxable as FTS/FIS under India-UK DTAA; TDS u/s 195 relief upheld</title>
      <link>https://www.taxtmi.com/highlights?id=93992</link>
      <description>ITAT held in favour of the appellant that amounts received for rendering IT support and non-IT services are not taxable as Fee for Technical Services/Fee for Included Services under the Act or the India-UK DTAA for purposes of TDS u/s 195. The Tribunal affirmed the DRP&#039;s factual finding that &quot;IT support&quot; and &quot;IT development&quot; services were dissimilar and found no reliable evidence that technical knowledge, skill or know-how was made available to the associated enterprise in India or that the assessee enabled the AE to perform the services independently. Consequently the additions treating receipts as FTS/FIS were deleted and both grounds of appeal were allowed.</description>
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      <pubDate>Sat, 08 Nov 2025 08:30:03 +0530</pubDate>
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