Service of notice and contractual debt acknowledgment preserved insolvency admission against a corporate guarantor despite limitation and natural just...
Original works exemption excludes standalone boulder transportation, leaving subcontracted railway-project transport services subject to service tax l...
Annual production capacity determinations excluding stenter galleries support refunds for unconstitutional excise levies without an unjust-enrichment ...
Vicarious liability for cheque dishonour requires specific allegations of responsibility and cheque signatory; generic director allegations cannot sus...
IT Resilience Index requires market infrastructure institutions to automate resilience scoring, early warnings, and continuous service-delivery monito...
ITAT allowed the appeal of the foreign taxpayer (a UK tax resident) and held that amounts received for provision of proprietary e-invoicing software and incidental training do not constitute "fees for technical services" under Article 13(4) of the India-UK DTAA. Relying on the HC's analysis, the tribunal found the requisite "make available" condition absent because the training merely enabled use of the taxpayer's e-platform and did not transfer technical know-how, processes, or rights that would allow the recipient to independently render the invoicing service. Consequently, such receipts do not accrue or arise in India as FTS and are not chargeable to tax under the Act.
ITAT allowed the appeal of the foreign taxpayer (a UK tax resident) and held that amounts received for provision of proprietary e-invoicing software and incidental training do not constitute "fees for technical services" under Article 13(4) of the India-UK DTAA. Relying on the HC's analysis, the tribunal found the requisite "make available" condition absent because the training merely enabled use of the taxpayer's e-platform and did not transfer technical know-how, processes, or rights that would allow the recipient to independently render the invoicing service. Consequently, such receipts do not accrue or arise in India as FTS and are not chargeable to tax under the Act.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
