Section 10A and related deductions: Tribunal rejects separate-undertaking claim, but allows loss set-off, ESOP cost and foreign tax credit in principl...
TDS u/s 195 - Management service cannot be characterized as ‘fees for included services’, and hence, not taxable in India as per the Double Taxation Avoidance Agreement (DTAA) between India and USA - disallowance u/s 40(a)(i) is not justified.
TDS u/s 195 - Management service cannot be characterized as ‘fees for included services’, and hence, not taxable in India as per the Double Taxation Avoidance Agreement (DTAA) between India and USA - disallowance u/s 40(a)(i) is not justified.
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