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Income from IT support services provided in India falls under Article 7; Assessing Officer directed to delete additions.
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....Income accrued in India - Service desk provided by the assessee to the employees of Tower Watson to monitor the IT related glitch - - services provided by the assessee is separate and it only collected the related cost to maintain the service desk. Therefore, it is a receipt which will fall under the Article 7 of the treaty. Hence, the addition proposed and sustained by the Ld.DRP are beyond the scope and accordingly Assessing Officer is directed to delete the same. - AT....