Income accrual in India not taxable as FIS/FTS. No tech services provided. Addition deleted. Software sale not FTS.

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....The ITAT considered the taxability of income in India as Fees for Included Service (FIS) or Fees for Technical Services (FTS) received by a non-resident corporate entity from its Indian subsidiary for management services. The AO failed to demonstrate that technical knowledge was made available by the assessee to the Indian subsidiary. The DRP mechanically endorsed the AO's view without proper examination. The ITAT directed deletion of the addition as FTS/FIS. Additionally, the ITAT found that the receipts from the sale of software to a bank were for software licenses, not services, and should not be treated as FTS. The ITAT held that the amount in dispute is not taxable as FTS and directed the AO to delete the addition.....