https://www.taxtmi.com/highlights?id=70144 Income deemed to accrue or arise in India - amounts received by the assessee from its Indian subsidiary towards IT and SAP charges - the services rendered under IT and SAP Services Agreement are not ancillary and subsidiary to the services rendered under the Technical Collaboration Agreement. Moreso, when the IT and SAP Services Agreement was in existence much prior to the Technical Collaboration Agreement. - The receipts in dispute cannot be treated as FTS under Article 12(4)(a) of India – Portugal DTAA - AT en-us Mon, 05 Jun 2023 12:33:46 +0530 Mon, 05 Jun 2023 12:33:46 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=70144 Income deemed to accrue or arise in India - amounts received by the assessee from its Indian subsidiary towards IT and SAP charges - the services rendered under IT and SAP Services Agreement are not ancillary and subsidiary to the services rendered under the Technical Collaboration Agreement. Moreso, when the IT and SAP Services Agreement was in existence much prior to the Technical Collaboration Agreement. - The receipts in dispute cannot be treated as FTS under Article 12(4)(a) of India – Portugal DTAA - AT Highlights Income Tax Mon, 05 Jun 2023 12:33:46 +0530 https://www.taxtmi.com/highlights?id=70144