Overseas Sales Commission Not "Fees for Technical Services" Under Income Tax Act; Misclassification Corrected.

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....The overseas sales commission received from Associated Enterprises (AEs) does not constitute "Fees for Technical Services" (FTS) u/s 9(1)(vii) of the Income Tax Act, as the services rendered are neither managerial nor consultancy in nature. The assessee company is a champion of indigenously developed technology in India, supplying to global customers with locally developed and globally registered patents. The associated entity performs pure sales functions, connecting potential customers and introducing the assessee to them, while the assessee predominantly handles the remaining activities. The Assessing Officer erroneously treated the overseas sales commission as FTS without appreciating that the associated entity does not render services .........