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Payment received by assessee from foreign company for business support services cannot be treated as FTS under Art. 12 (5) of India Netherlands DTAA: ITAT reiterates

ITAT noted that an identical issue was subject matter of consideration of the Tribunal in assessee’s own case, hence following the precedent, the Tribunal directed that the payment received in this case cannot be treated as FTS under Article 12 (5) of India Netherlands DTAA.

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Reopening of the assessment is indemonstrable in law as reasons inserted in Section 147 IT Act were not considered as evidence: ITAT

Payment received by assessee from foreign company for business support services cannot be treated as FTS under Art. 12 (5) of India Netherlands DTAA: ITAT reiterates