Form 26AS evidence requires successor-entity accounting verification after business transfer, while invoice-supported related-party advertising expend...
Money-laundering judgment timing requires awaiting the scheduled-offence decision despite continuation of the underlying trial where outcomes directly...
Accredited investor eligibility expands through securities-market exposure, while alternative investment fund disputes require prescribed resolution a...
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Fees for technical services (FTS) - India France DTAA - claiming the benefit of the restricted definition under India USA DTAA - Since the assessee has been found not to have ‘made available’ any technical knowledge, experience, skill, or know-how, therefore, Management Service Fees received by the assessee cannot be taxed under the provisions of Article 13 of the India France DTAA read with para 7 of the Protocol to the India France DTAA and Article 12(4) of India USA DTAA. - AT
Fees for technical services (FTS) - India France DTAA - claiming the benefit of the restricted definition under India USA DTAA - Since the assessee has been found not to have ‘made available’ any technical knowledge, experience, skill, or know-how, therefore, Management Service Fees received by the assessee cannot be taxed under the provisions of Article 13 of the India France DTAA read with para 7 of the Protocol to the India France DTAA and Article 12(4) of India USA DTAA. - AT
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