Amount of executive search fee is not ‘fee for technical services’ and hence not taxable

Spencer Stuart International B.V. Vs ACIT (ITAT Mumbai) ITAT Mumbai held that Executive search fee is not ‘fee for technical services’ under Article 12(5)(a) as well as 12(5)(b) of the India Netherlands Tax Treaty. Facts- The assessee is a tax resident of Netherlands and is entitled to the benefits of India-Netherlands tax treaty. The assessee is engaged in business of executive search services and related support services to group companies and third-party franchises. The case of the assessee was selected for scrutiny and vide draft assessment order dated 23/09/2021 passed u/s. 144C of th...