Data Management Charges Not Taxable as Technical Services Under Section 9(1)(vii)(b) Without Permanent Establishment

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....ITAT determined that remittances for data management charges do not constitute taxable technical services under section 9(1)(vii)(b). The non-resident entity lacks permanent establishment in India. Referencing precedent, the tribunal held that technical services are only taxable when the recipient cannot independently apply the technical knowledge without the service provider's aid. The tribunal directed the Assessing Officer to grant appropriate TDS credit and recalculate refund figures in accordance with legal provisions, allowing the grounds for statistical purposes.....