Introducing the “In Favour Of” filter in Case Laws.
- ⚖️ Instantly identify judgments decided in favour of the Assessee, Revenue, or Appellant
- 🔍 Narrow down results with higher precision
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Introducing the “In Favour Of” filter in Case Laws.
Try it now in Case Laws →
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of TDS u/s 195 - FTS in DTAA with USA - In view of Section 90(2) and clause 4(b) of Article 12 of the Treaty, the provisions of this Act would stand applicable only where fees for included services is make available technical knowledge - since as per ITAT there is no make available of the technical knowledge, it will not be FTS - neither TDS required nor disallowance 40(a)(ia)
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