Assessee, a Thailand-based company, was engaged in the business of the sale of cars, spare parts, etc. and was also responsible for exporting Honda motorcycles, automobiles, power products and components manufactured in Thailand to over 80 countries. During the year, assessee received certain payments in the nature of service receipts from the company, namely, HMSI in respect of certain services viz, infrastructure fee related to IT Services, software service and licence fees, etc.  Assessing Officer held that services rendered by assessee to HMSI were not directly connected to the business activities of assessee company and, thus, service receipts were taxable as ‘Other Income’ as per Article 22 of DTAA. DRP upheld the same. On appeal, the Tribunal held that   DRP had observed that assessee had not produced certain relevant portions of the agreement, specifically annexure defining services rendered under agreements, namely, service agreement of infrastructure services, Web EDI system maintenance agreement, etc., which were germane to the issue involved. Tribunal held that  DRP should revisit the issue upon examining documents which were not placed before it. Matter remanded. (AY. 2022-23)