ITAT Rules Subscription Fees for Foreign Income Not Technical Services u/s 9(1)(vii) of Income Tax Act.

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....Taxability of foreign income in India - business connection’ in India or not? - subscription services - ITAT came to the factual finding that the arrangement between assessee and the subscribers was for the provision of services for standard facility and not for “rendering of any technical, managerial or consultancy services” as provided in section 9(1)(vii) r/w Explanation 2 of the Act - Subscription fees not to be treated in the nature of fees for technical services (FTS) - Revenue appeal dismissed - HC....