Service Fees Not Taxable as FIS Under Article 12(4)(b) of India-USA DTAA, Following Previous Year's Treatment

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....ITAT ruled that service fees received were not taxable as Fees for Included Services (FIS) under Article 12(4)(b) of India-USA DTAA, consistent with previous treatment of consultancy and training fees in AY 2020-21. DRP findings remained identical across both assessment years. Interest under sections 234A and 234B to be levied as per law. AO directed to verify and allow TDS credit claims according to legal provisions. Regarding incorrect adjustment of refund recovery, AO instructed to examine assessee's claim and modify tax computation in accordance with law. Grounds 4 to 11 were allowed in favor of assessee.....