2024 (9) TMI 1098

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.... the Assessment Year 2019-20. 2. Shri Vishal Kalra, appearing on behalf of the assessee submitted that the solitary issue raised by the assessee in appeal is against the addition made on account of Management Service Fees. 3. Narrating facts of the case, the ld. Counsel submitted that the assessee is a tax resident of Singapore. During the period relevant to assessment year under appeal, the assessee received Management Service Fee amounting to Rs. 2,62,91,790/- from its associated enterprises in India Flowserve India Controls P. Ltd., (FICPL) for rendering management service. The service rendered by assessee includes planning and analysis, finance, human resources, training, engineering services, etc. FICPL while making aforesaid pay....

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....hat the assessee has not furnished complete details of the exact nature of services rendered by the assessee to FICPL, and thus, upheld the addition. The ld. Counsel submitted that neither the CIT(A), nor the AO have examined the documents furnished by the assessee. The assessee had furnished all the relevant documents to substantiate that the services rendered by the assessee does not fall within the ambit of 'fee for technical services' within the meaning of Article 12 of India-Singapore DTAA, hence, not taxable in India. The aforesaid services do not "make available" any technical knowhow or transfer of technology. The counsel for the assessee prayed for deleting the addition. 6. Per contra, Shri S.N. Pandey, Sr. DR representing the D....