HCL AUSTRALIA SERVICES PTY LIMITED,DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX, DELHI

In the result, similar grounds of appeal, in all the captioned

Bench: Shri Vikas Awasthy & Shri Naveen Chandra

section 9(1) (vii)(b) of the Act. iii) Third, the amount received by the assessee, a resident of Singapore, for onsite services was not liable to tax in India, in terms of the applicable DTAA as such services did not “make available” any technical knowledge, skill or experience or consist of the transfer of any technical plan or design