Abb Fz-Llc vs Deputy commissioner of income tax(International taxation)

Whether payments received by a non-resident UAE company for regional services constitute 'royalty' under the Income Tax Act and India-UAE DTAA, and whether such income is taxable in India in the absence of a specific Fees for Technical Services (FTS) clause in the DTAA --- Held No; Whether the domestic Act prevails when the DTAA is silent on taxability of a particular payment --- Held No; Whether interest under section 234B and penalty under section 271(1)(c) are leviable --- Held No.