Amount received for business support services not treatable as FTS

Inteva Products Netherlands BV Vs ACIT (ITAT Delhi) ITAT Delhi held that amount received on account of business support services cannot be treated as ‘Fees for Technical Services’ (FTS) under Article 12(5) of India Netherlands DTAA and hence addition towards the same unsustainable. Facts- Assessee is a company incorporated in Netherlands and is a tax resident of Netherlands. For the AY 2018-19, assessee filed return of income on 27.11.2018 showing income of Rs.48,50,157/-. During the course of assessment, AO observed that assessee has received income of Rs.48,50,157/- on account of interes...