Sandvik IT Services AB. v. ACIT(IT) (2021) 191 ITD 290 (Pune) (Trib.)

S. 9(1)(vii) : Income deemed to accrue or arise in India-Fees for technical services-Service help agreement-Proof of service was not furnished-Matter remanded-DTAA-India-Sweden. [Art. 12]

Following the earlier year order amount received by a Swedish company from Indian entity for providing IT support services to latter held to be not taxable. Other three entities   since assessee could not furnish proof of correct nature of services with help of any agreement, matter was to be remitted to file of Assessing Officer for a fresh determination of issue.  (AY. 2017-18)