Allowing the appeal of the assesse , the Tribunal held that; Payments made towards allocation of expenses cannot be treated as fees for technical services ( AY. 2005 -06)
Credit Agricole Corporate & Investment Bank v. DIT (IT) (2018) 168 ITD 553 (Mum) (Trib.)
S. 9(1)(vii):Income deemed to accrue or arise in India – Fees for technical services –Payments made towards allocation of expenses cannot be treated as fees for technical services – DTAA-India – France [ Art . 13 ]