https://www.taxtmi.com/highlights?id=66047 TDS liability - the findings of the Ld.CIT(A) that halal certification involved technical knowhow being made available to the assessee, is incorrect on facts. The payment made by the assessee to IFANCA therefore for halal certification and supervision charges, did not qualify as “Included Services” in terms of Article 12(4) of the DTAA with USA and the said payment, we hold, did not qualify for withholding tax in terms of the DTAA - AT en-us Fri, 14 Oct 2022 15:15:36 +0530 Fri, 14 Oct 2022 15:15:36 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=66047 TDS liability - the findings of the Ld.CIT(A) that halal certification involved technical knowhow being made available to the assessee, is incorrect on facts. The payment made by the assessee to IFANCA therefore for halal certification and supervision charges, did not qualify as “Included Services” in terms of Article 12(4) of the DTAA with USA and the said payment, we hold, did not qualify for withholding tax in terms of the DTAA - AT Highlights Income Tax Fri, 14 Oct 2022 15:15:36 +0530 https://www.taxtmi.com/highlights?id=66047