Section 44DA not applicable when the amount received doesn’t qualify as royalty/ FTS

DCIT Vs Technip France SAS (ITAT Delhi) Held that as the amount received by the assessee is not in the nature of royalty or FTS, section 44DA of the Income Tax Act will not apply. Facts- The assessee is a non-resident corporate entity incorporated under the laws of France and a tax resident of the said country. Assessee is primarily engaged in engineering, procurement, and construction business for oil production- off-shore and on-shore, refining petrochemicals, fertilizers, chemical fertilizers, non-conventional energy and submarine pipelines, etc. The assessee had entered into contracts with...