Business expenditure deduction requires proof of genuine commission payments and commercial allowability; turnover growth alone cannot validate the cl...
Article 8 treaty coverage excluded third-party airline support services, while documented demonetisation cash receipts remained accepted business inco...
Functional comparability under TNMM requires highway contract benchmarks to reflect operation, maintenance and transfer activities, requiring fresh be...
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The assessee's income received from Indian customers as Fee for Technical Services (FTS)/Fee for Included Services (FIS) u/s 9(1)(vii) of the Act and Article 12(4) of India-USA Double Taxation Avoidance Agreement was examined. The Assessing Officer (AO) observed that the assessee provided user-specific services involving human intervention, beyond mere content services. However, the AO's findings were self-contradictory, acknowledging the assessee as an aggregation service provider but denying its role as a mere aggregator. The AO failed to establish that the assessee provided technical services through its online platform or transferred technical knowledge, know-how, or skills to enable independent utilization by recipients. Relying on precedents, the Appellate Tribunal held that the receipts did not qualify as FIS under Article 12(4) of the India-USA tax treaty, allowing the assessee's appeals.
The assessee's income received from Indian customers as Fee for Technical Services (FTS)/Fee for Included Services (FIS) u/s 9(1)(vii) of the Act and Article 12(4) of India-USA Double Taxation Avoidance Agreement was examined. The Assessing Officer (AO) observed that the assessee provided user-specific services involving human intervention, beyond mere content services. However, the AO's findings were self-contradictory, acknowledging the assessee as an aggregation service provider but denying its role as a mere aggregator. The AO failed to establish that the assessee provided technical services through its online platform or transferred technical knowledge, know-how, or skills to enable independent utilization by recipients. Relying on precedents, the Appellate Tribunal held that the receipts did not qualify as FIS under Article 12(4) of the India-USA tax treaty, allowing the assessee's appeals.
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