IT Support Payments Not FTS under Article 12 of India-Netherlands DTAA

Shell Information Technology International BV Vs DCIT (ITAT Mumbai) Amount paid for IT Support Services should not be considered as FTS under Article 12 of India – Netherlands DTAA Conclusion: Payments for IT support services were not considered fees for technical services under the provisions of Article 12 of the India-Netherlands Double Taxation Avoidance Agreement ( DTAA ) as IT Support Services were intricately connected with the provision of Software Access Service, the IT Support Services would also not qualify as ‘royalties’ in terms of Article 12(4) of the DTAA or as ‘Fee for T...