Royalties/Fees for technical services – Managerial service : Where assessee, a German company, entered into an agreement with an Indian company, SIPL, for promotion, sale and distribution of print and electronic books and journals published by SIPL and received commission for providing said services, since assessee only rendered support to business operations and no special skills or knowledge were required to render services that were contemplated under agreement, commission received by assessee could not be treated as FTS – Springer Nature Customer Service Center GmbH v. ACIT – [2024] 164 taxmann.com 354 (Delhi – Trib.)
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