Sum received for providing technical services not taxable as FTS if recipient can't perform such services on its own

INTERNATIONAL TAXATION: Where assessee received certain amount for providing technical services under General Service Agreement (GSA) to its group concerns, Assessing Officer erred in taxing said receipts as 'Fees for Included Services' (FIS) since there was no clause in GSA that recipient would be able to perform such services of its own without any further assistance of assessee

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