The Calcutta High Court upheld the ITAT's decision, ruling that

The Calcutta High Court upheld the ITAT's decision, ruling that 

The Calcutta High Court upheld the ITAT's decision, ruling that the assessee is only rendering advisory services, it cannot be treated as included services under Article 12(4)(b) of the India-US Double Taxation Avoidance Agreement. As a result, consideration for advisory services does not amount to FTS and cannot be treated as Fees for Included Services under Article 12(4)(b) of the India-US Double Taxation Avoidance Agreement (DTAA). (CIT(IT&TP) vs the Timken Company)



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