Once it is proved that receipt is in nature of managerial service, same cannot be treated as FTS

Wolters Kluwer Financial Services Belgium NV Vs DCIT (ITAT Delhi)

ITAT Delhi held that once the assessee was able to demonstrate that the amount received is in the nature of managerial services, it cannot be treated as FTS on estimated basis. Such receipt not being FTS is not taxable in India.

Facts-

The assessee is a non-resident corporate entity incorporated under the laws of Belgium and is a tax resident of Belgium. As observed by the

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