ITAT Delhi held that AO is bound to follow the directions of DRP. Accordingly, final assessment order passed by AO without implementing direction of DRP makes the assessment order void-ab-initio.
ITAT Delhi held that payments received by the assessee qualifies as Fees for Technical Services (FTS) under sub-clause (4) of Article 12 of Indo – Singapore DTAA and hence rightly brought to tax @10%.