Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
The Income Tax Appellate Tribunal (ITAT) examined the taxability of income in India regarding management service fees. For quality development and training services, the assessee offered the income to tax, conceding transfer of know-how and technology. Regarding information technology services, the CIT(Appeals) concluded that the fee was not taxable in India as the 'make available' criteria under the India-Singapore tax treaty was not satisfied. For other services like planning analysis/corporate development, human resources, and finance, the CIT(Appeals) upheld the addition solely on the ground that the assessee did not furnish complete details to determine the exact nature of services. The assessee contended that relevant documents were furnished but not examined. The ITAT restored this issue to the CIT(Appeals) to re-examine the documents furnished by the assessee and pass a speaking order regarding the taxability of planning & analysis/corporate development services, human resources & finance services, in accordance with law.
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