https://www.taxtmi.com/caselaws?id=242388 The Authority held that the Applicant's advance ruling application regarding payments under the Management Service Agreement with Aircom India was admissible despite objections raised by the Revenue. The issues of whether the payments constituted 'fees for technical services' or 'royalty' under the India-UK Treaty were deemed admissible as they were not pending before the Income-tax Authorities. The Authority also allowed consideration of whether the payments should be treated as business income and addressed the applicability of withholding tax under section 195 of the Income-tax Act. en-us Fri, 10 Jan 2014 00:00:00 +0530 Mon, 07 Apr 2014 17:19:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=242388 The Authority held that the Applicant's advance ruling application regarding payments under the Management Service Agreement with Aircom India was admissible despite objections raised by the Revenue. The issues of whether the payments constituted 'fees for technical services' or 'royalty' under the India-UK Treaty were deemed admissible as they were not pending before the Income-tax Authorities. The Authority also allowed consideration of whether the payments should be treated as business income and addressed the applicability of withholding tax under section 195 of the Income-tax Act. Case-Laws Income Tax Fri, 10 Jan 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=242388