Shared Services Payments Not Taxable as Fees for Technical Services, No Independent Technical Knowledge Transfer Found.

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....Income deemed to accrue or arise in India - shared services - the CIT(A) has failed to appreciate that the year on year rendition of services by the assessee to the Indian entity proves that technical knowledge is not transferred or made available to the Indian entity for independently function without the aid of the assessee. We therefore agree with the plea of the assessee and hold that the sum received towards shares services were not in the nature of FTS and cannot be brought to tax in India as “FTS” - AT....