https://www.taxtmi.com/caselaws?id=792974 IT recharge fees were described as falling within the concessional tax regime under section 115A and, on treaty analysis, as not constituting fees for technical services under Article 13 of the India-UK DTAA because the services were routine IT support and did not make available technical knowledge, skill, know-how or process. The note also records that additions based on Form 26AS mismatches and short TDS credit required factual reconciliation and were sent back for verification and consequential credit. Interest under section 234B was stated to be unsustainable for a non-resident where the income was subject to TDS in the relevant pre-amendment year, while the section 234C issue was left for verification. en-us Fri, 29 May 2026 00:00:00 +0530 Sat, 06 Jun 2026 08:42:22 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=792974 IT recharge fees were described as falling within the concessional tax regime under section 115A and, on treaty analysis, as not constituting fees for technical services under Article 13 of the India-UK DTAA because the services were routine IT support and did not make available technical knowledge, skill, know-how or process. The note also records that additions based on Form 26AS mismatches and short TDS credit required factual reconciliation and were sent back for verification and consequential credit. Interest under section 234B was stated to be unsustainable for a non-resident where the income was subject to TDS in the relevant pre-amendment year, while the section 234C issue was left for verification. Case-Laws Income Tax Fri, 29 May 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=792974