Tax Dispute Resolved: Foreign Fabrication Charges Not Taxable Under Article 12(3) and 12(4)(a) Provisions

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....ITAT adjudicated a tax dispute involving technical services income from an international transaction. The tribunal determined that fabrication charges received by a foreign entity were not taxable in India. Applying principles from a precedent case, the tribunal concluded that tax-efficient structuring of multinational group transactions does not automatically invalidate the arrangement. Specifically, the tribunal found that Article 12(3) and 12(4)(a) provisions could not be invoked to tax the income. Consequently, the tribunal upheld the assessee's plea and deleted the contested tax addition, rendering a decision favorable to the taxpayer.....