Court Reviews Taxation of Offshore Sales and Services Under Article 12 of India-Ireland DTAA.

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....Income accrued in India - receipt from offshore sale of goods - rendering supporting services - fees for included services (FIS) - Article 12 of India-Ireland DTAA - A.O has not established that how the amount received by the assessee was related to rendering of any services by the assessee. A.O/DRP have not controverted the facts established from the invoices on sale of equipments as discussed supra in this order. - AT....