Technical Service Fees Not Taxable: Corporate Allocation Charges Exempt Under DTAA and Section 9(1)(vii)

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....HC affirmed ITAT's ruling regarding income tax treatment of technical service fees from Indian customers. The court found no taxable technical service fees under India-USA DTAA or Section 9(1)(vii). Corporate allocation charges were deemed non-taxable as the assessee did not render direct services, transfer skills, or send employees to India. The court concluded that the ITAT's fact-specific findings were sound and no substantial legal question existed, effectively upholding the lower tribunal's assessment of non-taxability of the disputed income streams.....