https://www.taxtmi.com/highlights?id=68610 Income deemed to accrue or arise in India - Fee for Technical Services (FTS)/ Fee for Included Services (FIS) - the services provided by the assessee under the marketing support service agreement are neither in the nature of technical or consultancy services under Article 12(4) of India – USA Tax Treaty. Even, assuming that it is in the nature of consultancy services, however, the ‘make available’ condition provided under Article 12(4)(b) of the Tax Treaty is not satisfied. - AT en-us Mon, 06 Mar 2023 11:18:35 +0530 Mon, 06 Mar 2023 11:18:35 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=68610 Income deemed to accrue or arise in India - Fee for Technical Services (FTS)/ Fee for Included Services (FIS) - the services provided by the assessee under the marketing support service agreement are neither in the nature of technical or consultancy services under Article 12(4) of India – USA Tax Treaty. Even, assuming that it is in the nature of consultancy services, however, the ‘make available’ condition provided under Article 12(4)(b) of the Tax Treaty is not satisfied. - AT Highlights Income Tax Mon, 06 Mar 2023 11:18:35 +0530 https://www.taxtmi.com/highlights?id=68610