Objective characteristics and principal use govern mining-tyre classification, while fresh advance ruling applications may rely on additional technica...
Administrative fraud classification suspension does not halt independent criminal investigation or warrant-based searches into alleged economic offenc...
Income deemed to accrue or arise in India - Fee for Technical Services (FTS)/ Fee for Included Services (FIS) - the services provided by the assessee under the marketing support service agreement are neither in the nature of technical or consultancy services under Article 12(4) of India – USA Tax Treaty. Even, assuming that it is in the nature of consultancy services, however, the ‘make available’ condition provided under Article 12(4)(b) of the Tax Treaty is not satisfied. - AT
Income deemed to accrue or arise in India - Fee for Technical Services (FTS)/ Fee for Included Services (FIS) - the services provided by the assessee under the marketing support service agreement are neither in the nature of technical or consultancy services under Article 12(4) of India – USA Tax Treaty. Even, assuming that it is in the nature of consultancy services, however, the ‘make available’ condition provided under Article 12(4)(b) of the Tax Treaty is not satisfied. - AT
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