Tribunal held that professional fees paid for advocate to foreign attorneys in connection with IPR services, the payments were in the nature of pure reimbursement was not accepted. The Assessing officer was directed to examine the taxability of provision with reference to DTAA. (AY. 2011-12)
ACIT v. Subhatosh Majumder (2021) 200 DTR 113 (Kol.)(Trib.)
S. 40(a)(i) : Amounts not deductible-Deduction at source-Non-resident-Fees for technical services-Professional fees paid for advocate to foreign attorneys in connection with IPR services-Directed to examine the taxability of provision with reference to DTAA-Payments were in the nature of pure reimbursement was not accepted. [S. 9(1)(vii)(b), 195]