Helicopter charter classification requires effective control analysis, while territorial performance, reasoned credit orders and wilful suppression de...
Specified fund definition expands PAN exemption eligibility for registered alternative investment funds and qualifying International Financial Service...
Tax exemption for specified legal-services authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and...
Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
Income accrued in India - Fee for Technical/Included Services - whether the amount received by the assessee for various services, commonly known as centralized services, will fall within the ambit of FIS under Article 12(4)(a) of the Treaty? - the fee received by the assessee under the Centralized Services Agreement cannot be treated as FIS either under Article 12(4)(a) or 12(4)(b) of the India–US Tax Treaty. As a natural corollary, it can only be treated as business income of the assessee. Hence, in absence of a PE in India, it will not be taxable. - AT
Income accrued in India - Fee for Technical/Included Services - whether the amount received by the assessee for various services, commonly known as centralized services, will fall within the ambit of FIS under Article 12(4)(a) of the Treaty? - the fee received by the assessee under the Centralized Services Agreement cannot be treated as FIS either under Article 12(4)(a) or 12(4)(b) of the India–US Tax Treaty. As a natural corollary, it can only be treated as business income of the assessee. Hence, in absence of a PE in India, it will not be taxable. - AT
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4805
Join Channel
TaxTMI 
