Concessional penalty for search-disclosed unreconciled jewellery applies where substantive disclosure conditions are met despite omission from origina...
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)
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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