The Delhi bench of the ITAT has held that payments received

The Delhi bench of the ITAT has held that payments received

The Delhi bench of the ITAT has held that payments received from foreign companies on account of business support services cannot be treated as fees for technical services under the India-Netherlands DTAA because Article 12(5) of the India-Netherlands DTAA reveals that it does not include managerial services within fees for technical services.



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