https://www.taxtmi.com/caselaws?id=380807 Disallowance for alleged failure to deduct tax at source on payments to foreign entities was examined under the India-Finland DTAA, with the central question being whether the services constituted fees for technical services and whether the treaty "make available" condition was satisfied. The Tribunal noted that its earlier order in the assessee's own case had already remanded the matter for factual verification, including whether the individual recipients met the requirements of Article 15 of the DTAA. Treating the relevant facts as identical, it followed that earlier view and remanded the issue for fresh adjudication by the Assessing Officer. en-us Wed, 27 Mar 2019 00:00:00 +0530 Tue, 28 May 2019 13:18:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=380807 Disallowance for alleged failure to deduct tax at source on payments to foreign entities was examined under the India-Finland DTAA, with the central question being whether the services constituted fees for technical services and whether the treaty "make available" condition was satisfied. The Tribunal noted that its earlier order in the assessee's own case had already remanded the matter for factual verification, including whether the individual recipients met the requirements of Article 15 of the DTAA. Treating the relevant facts as identical, it followed that earlier view and remanded the issue for fresh adjudication by the Assessing Officer. Case-Laws Income Tax Wed, 27 Mar 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=380807