https://www.taxtmi.com/caselaws?id=468395 Manpower support receipts were treated as fees for technical services only if the arrangement clearly made available technical knowledge, skill, know-how or processes under section 9(1)(vii) and Article 12(4) of the India-US DTAA; on the facts stated, mere support or collaboration was insufficient. The reimbursement from PhonePe required fresh factual verification because the record did not clearly establish the nature of the secondment and service arrangement. Interest under sections 234A and 234B was described as consequential and mandatory, while the disputed additional interest component needed identification of the correct charging provision. TDS credit was to be examined and allowed if admissible, and the penalty challenge under section 270A was premature at the initiation stage. en-us Wed, 10 Dec 2025 00:00:00 +0530 Mon, 04 May 2026 19:59:01 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=468395 Manpower support receipts were treated as fees for technical services only if the arrangement clearly made available technical knowledge, skill, know-how or processes under section 9(1)(vii) and Article 12(4) of the India-US DTAA; on the facts stated, mere support or collaboration was insufficient. The reimbursement from PhonePe required fresh factual verification because the record did not clearly establish the nature of the secondment and service arrangement. Interest under sections 234A and 234B was described as consequential and mandatory, while the disputed additional interest component needed identification of the correct charging provision. TDS credit was to be examined and allowed if admissible, and the penalty challenge under section 270A was premature at the initiation stage. Case-Laws Income Tax Wed, 10 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=468395