Retrospective cancellation of charitable registration under section 12AB(4) was unsustainable; related-party benefit allegations did not prove nongenu...
Merger control notice and disclosure rules: Supreme Court limits penalties, rejects reopening of approved combination, and sets aside adverse findings...
Page of 4807
Press 'Enter' after typing page number.
2741 to 2760 of 96140 Results
❮
❯
❯❯
0 / 200
Expand Note
Add to Folder
No Folders have been created
+
Are you sure you want to delete "My most important" ?
The Appellate Tribunal addressed the taxability of payments as Fee for Technical Services (FTS) u/s 195. The Assessing Officer (AO) found the services provided by the Associate Enterprise (AE) to be FTS, upheld by CIT(A). The assessee argued that the AE did not "make available" knowledge, as required u/s 9 of the Act and Article 12(4)(b) of the DTAA. Referring to relevant cases, the Tribunal held that for FTS taxability, services must not only be technical but also "make available" knowledge. As the AO failed to prove the AE provided technical knowledge, the appeal was allowed, rejecting the AO's reliance on overruled cases.
The Appellate Tribunal addressed the taxability of payments as Fee for Technical Services (FTS) u/s 195. The Assessing Officer (AO) found the services provided by the Associate Enterprise (AE) to be FTS, upheld by CIT(A). The assessee argued that the AE did not "make available" knowledge, as required u/s 9 of the Act and Article 12(4)(b) of the DTAA. Referring to relevant cases, the Tribunal held that for FTS taxability, services must not only be technical but also "make available" knowledge. As the AO failed to prove the AE provided technical knowledge, the appeal was allowed, rejecting the AO's reliance on overruled cases.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4807 
Join Channel 
