9911796707
TMI Blog2024 (9) TMI 1098X X X X Extracts X X X X X X X X Extracts X X X X ..... payable in respect of information technology services is not taxable in India. Other services i.e. planning analysis/corporate development, human resources and finance, the CIT(A) has upheld the addition solemnly on the ground that the assessee has not furnished complete details, therefore, exact nature of services could not be determined. Contention of the assessee is that all relevant documents were furnished before the AO, as well as the CIT(A), but the same have not been examined by the First Appellate Authority. Taking into consideration entire facts, we deem it appropriate to restore this issue back to the file of the CIT(A), for re-examine the documents already furnished by the assessee available on record and also any other document ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e for impugned assessment year on 30.11.2019, thereafter the assessee filed revised return of income offering an amount of Rs. 32,95,798/- as tax on fees received towards quality development and training services that make available technical skill, knowledge etc. as per the provision of India-Singapore DTAA. As regards, other services there was no transfer of knowhow or any technical skill was made available, hence, the fee in respect of other services is not taxable in India as per the provisions of India- Singapore DTAA. The ld. Counsel pointed that the assessee had made detailed submissions regarding operation of provisions of India-Singapore DTAA, the Assessing Officer (AO) has reproduced part of assessee s submissions made on 29.09.20 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... sessee. The ld. DR submits that the assessee has failed to substantiate its claim as the relevant documents were not furnished by the assessee. 7. We have heard the submissions made by rival sides and have examined the orders of authorities below. The assessee has rendered following management services to its AE in India:- (i) Information Technology Services; (ii) Planning and Analysis/Corporate Development Services; (iii) Human Resources; (iv) Finance Services; and (v) Quality Development and Training. In so far as Quality Development and Training services are concerned, the assessee has offered the same to tax, conceding that there has been transfer of knowhow and technology. As regards Information Technology Services, the CIT(A) after ex ..... X X X X Extracts X X X X X X X X Extracts X X X X
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