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Nalco Co. v. ACIT(2023) 222 TTJ 1002 (Pune) (Trib)

S. 9(1)(vii) : Income deemed to accrue or arise in India-Fees for technical services-No evidence was available to ascertain the precious nature of actual services rendered-Matter remanded to the Assessing Officer-DTAA-India-USA. [S. 90, art. 12(4)]

 

Held that there is no evidence was available to ascertain the precious nature of actual services rendered. Accordingly the matter is remanded to the Assessing Officer to determine its taxability or otherwise as per art. 12 of DTAA of the India and USA. (AY. 2016-17)