Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
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ITAT held that passenger system services provided by a US-based company to an Indian airline do not constitute Fees for Technical Services (FTS) under Article 12 of India-USA DTAA. The tribunal determined that no specific technology was made available to the Indian entity, and the services were rendered using standard software supported by the service provider's data center. Consequently, the tribunal upheld the CIT(A)'s order, finding the receipts non-taxable in India, effectively dismissing the revenue department's contentions regarding taxation under section 9(1)(vii) of the Income Tax Act as procedurally academic.
ITAT held that passenger system services provided by a US-based company to an Indian airline do not constitute Fees for Technical Services (FTS) under Article 12 of India-USA DTAA. The tribunal determined that no specific technology was made available to the Indian entity, and the services were rendered using standard software supported by the service provider's data center. Consequently, the tribunal upheld the CIT(A)'s order, finding the receipts non-taxable in India, effectively dismissing the revenue department's contentions regarding taxation under section 9(1)(vii) of the Income Tax Act as procedurally academic.
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