Current account treatment of overseas tournament services removed most FEMA findings, but excess EEFC remittance and delayed repatriation remained bre...
Modification of bail conditions remains available through inherent jurisdiction where onerous deposits undermine justice and cannot recover disputed d...
Merchant banker regulation consolidates registration, governance, capital, reporting, outsourcing and investor-protection requirements under an update...
Authentication of paper assessment orders upheld, while qualifying repairs, consumables and vendor advance write-offs remain deductible business claim...
Page of 4803
Press 'Enter' after typing page number.
701 to 720 of 96046 Results
❮
❯
❯❯
0 / 200
Expand Note
Add to Folder
No Folders have been created
+
Are you sure you want to delete "My most important" ?
ITAT held that the consideration received by the assessee, a Netherlands tax resident, for rendering business support services to its Indian group entity is not taxable in India as fee for technical services under Article 12 of the India-Netherlands DTAA. On examining the nature of services, ITAT concluded they are predominantly managerial and Article 12(5) does not encompass managerial services within FTS. Further, even on an arguendo basis, ITAT found that the "make available" condition was not satisfied, as no technical knowledge, experience, skill or know-how was made available to enable independent use by the recipient. Accordingly, the addition made by the AO was deleted and the assessee's appeal allowed.
ITAT held that the consideration received by the assessee, a Netherlands tax resident, for rendering business support services to its Indian group entity is not taxable in India as fee for technical services under Article 12 of the India-Netherlands DTAA. On examining the nature of services, ITAT concluded they are predominantly managerial and Article 12(5) does not encompass managerial services within FTS. Further, even on an arguendo basis, ITAT found that the "make available" condition was not satisfied, as no technical knowledge, experience, skill or know-how was made available to enable independent use by the recipient. Accordingly, the addition made by the AO was deleted and the assessee's appeal allowed.
Note: It is a system-generated summary and is for quick reference only.