https://www.taxtmi.com/highlights?id=67552 Fees for technical services’ (‘FTS’) - The conclusion drawn by the AO is not proper because the training simply advances the skill of the recipient-employees but falls short of providing any technical knowledge, experience, skill that enables the employees “to apply the technology contained therein”. - decision of the AO in treating the amount as FTS, is not correct because such consideration does not fall within the purview of FTS under Article 12(4) of the DTAA read with Article 12(4) of the DTAA between India- Portuguese - AT en-us Sat, 07 Jan 2023 17:18:17 +0530 Sat, 07 Jan 2023 17:18:17 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=67552 Fees for technical services’ (‘FTS’) - The conclusion drawn by the AO is not proper because the training simply advances the skill of the recipient-employees but falls short of providing any technical knowledge, experience, skill that enables the employees “to apply the technology contained therein”. - decision of the AO in treating the amount as FTS, is not correct because such consideration does not fall within the purview of FTS under Article 12(4) of the DTAA read with Article 12(4) of the DTAA between India- Portuguese - AT Highlights Income Tax Sat, 07 Jan 2023 17:18:17 +0530 https://www.taxtmi.com/highlights?id=67552