Supervisory permanent establishment requires project-wise duration and qualifying construction nexus; offshore supplies and salary reimbursements rema...
Transfer-pricing comparability permits fresh objections and filters where software service comparables are functionally unsuitable for arm's-length pr...
Territorial rendering requirement excludes China-based management and consultancy services from fees for technical services under the India-China DTAA...
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The Appellate Tribunal (ITAT) examined the taxability of sales commission as Fees for Technical Services (FTS) under the Act and India-USA DTAA. The Tribunal held that the sales commission received did not meet the definition of "FTS" under both the Act and the DTAA. It was noted that since the payer was previously held exempt from tax on commission payments, the same applies to the recipient. Ground No.3 was allowed in favor of the assessee, determining that sales commission is not taxable.
The Appellate Tribunal (ITAT) examined the taxability of sales commission as Fees for Technical Services (FTS) under the Act and India-USA DTAA. The Tribunal held that the sales commission received did not meet the definition of "FTS" under both the Act and the DTAA. It was noted that since the payer was previously held exempt from tax on commission payments, the same applies to the recipient. Ground No.3 was allowed in favor of the assessee, determining that sales commission is not taxable.
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