Alternate statutory remedy governs GST assessment challenge, with statutory appeal preserved and limitation objection barred for the permitted filing ...
Income deemed to accrue or arise in India - Fees for Technical Services (FTS)/Fees for Included Services (FIS) - Assessee is not the ultimate beneficiary of the sum in question nor did it render any service to TIL. Further, there was no evidence which was brought on record to show that the technical skill, knowledge etc. were made available to TIL by the assessee. - HC
Income deemed to accrue or arise in India - Fees for Technical Services (FTS)/Fees for Included Services (FIS) - Assessee is not the ultimate beneficiary of the sum in question nor did it render any service to TIL. Further, there was no evidence which was brought on record to show that the technical skill, knowledge etc. were made available to TIL by the assessee. - HC
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