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    Income Tax

    To “make available” technical knowledge, mere provisions of ser...

    Providing a Service Isn't Enough: Recipients Must Be Empowered to Perform Independently Under India-USA DTAA.

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    Income TaxMay 31, 2012Case LawsAT

    To “make available” technical knowledge, mere provisions of service was not enough and the payer had to be enabled to perform services himself. The department’s argument that the amendments by the Finance Act, 2012 changes the position is not acceptable, since there is no change in the DTAA between India and USA and the DTAA prevails where it is favourable to the assessee; - AT

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