Income from Services to Non-Residents Not Taxable; No Evidence of Technical Knowledge Transfer Under Article 12(4.

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....Income accrued in India - Rendering services to non-resident entities - Though, the assessing officer has generally observed that in course of providing services to the assessee, the non-resident entities have made available technical knowledge, know-how, processes to the assessee. However, no substantive material has been brought on record by him to back such conclusion. - it is very much clear, the conditions of Article 12(4) of the tax treaty are not fulfilled. - AT....