ITAT ruled that hire payments to Belgium are not taxable due to DTAA. TP adjustment using CUP method allowed based on consistency. TDS credit to be verified.

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....The ITAT ruled on various tax issues. Regarding TDS u/s 195, payments for bare-boat charter hire were not subject to tax in India due to DTAA with Belgium. TP adjustment for hire payments to AEs was allowed using CUP method, rejecting TNMM. Adjustment for technical services payment was upheld based on project turnover. Short-credit of TDS was directed to be verified and allowed by AO. The decisions were based on legal principles and prior case rulings, ensuring fair treatment of the taxpayer.....