Political contribution deductions require genuine transactions; banking records and party registration alone cannot defeat evidence of accommodation e...
Post-death GST liability permits fresh proceedings against legal representatives, while discontinued-business recovery remains limited to the inherite...
Non-confirmation of FEMA seizure prevents adjudicators from overriding pending appellate findings on recorded reasons and suspected foreign asset hold...
Fees for Technical Services (FTS) - The AO himself has stated that some of the services are of the nature of FTS. Thus, AO clearly admits that all the services rendered by the assessee are not in the nature of FTS. In spite of that the AO has treated the entire receipts as FTS and added at the hands of the assessee. - Further, the ‘make available’ condition provided under Article 13(4)(c) remains non-compliant. That being the position, the receipts would not fall within the definition of FTS as provided under Article 13(4) of India – UK DTAA. - AT
Fees for Technical Services (FTS) - The AO himself has stated that some of the services are of the nature of FTS. Thus, AO clearly admits that all the services rendered by the assessee are not in the nature of FTS. In spite of that the AO has treated the entire receipts as FTS and added at the hands of the assessee. - Further, the ‘make available’ condition provided under Article 13(4)(c) remains non-compliant. That being the position, the receipts would not fall within the definition of FTS as provided under Article 13(4) of India – UK DTAA. - AT
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
