https://www.taxtmi.com/caselaws?id=59714 The Tribunal upheld the CIT(A)'s decision, affirming that the assessee qualified as a "resident" of Germany under the India-Germany DTAA and was eligible for the beneficial tax rate of 10% on royalties and fees for technical services. Additionally, the Tribunal agreed with the deletion of interest u/s 234B, ruling that as a non-resident subject to TDS on all payments, the assessee was not liable for advance tax. The Revenue's appeal was dismissed, confirming the assessee's entitlement to the DTAA's favorable tax treatment and exemption from interest u/s 234B. en-us Fri, 04 Jul 2008 00:00:00 +0530 Fri, 20 Jul 2012 12:41:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=59714 The Tribunal upheld the CIT(A)'s decision, affirming that the assessee qualified as a "resident" of Germany under the India-Germany DTAA and was eligible for the beneficial tax rate of 10% on royalties and fees for technical services. Additionally, the Tribunal agreed with the deletion of interest u/s 234B, ruling that as a non-resident subject to TDS on all payments, the assessee was not liable for advance tax. The Revenue's appeal was dismissed, confirming the assessee's entitlement to the DTAA's favorable tax treatment and exemption from interest u/s 234B. Case-Laws Income Tax Fri, 04 Jul 2008 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=59714