https://www.taxtmi.com/caselaws?id=442485 Receipts for IT services rendered in Finland were treated as taxable in India under the India-Finland DTAA because the services were for use by Indian group entities, and the absence of a make available clause did not prevent taxation. Corporate guarantee fees were treated as income from other sources under Article 21, as the guarantee support was ancillary to shareholder support and connected with the Indian subsidiary. Matters relating to refund interest and TDS credit were remanded for verification and fresh consideration after hearing the assessee. en-us Tue, 29 Aug 2023 00:00:00 +0530 Wed, 04 Dec 2024 15:00:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=442485 Receipts for IT services rendered in Finland were treated as taxable in India under the India-Finland DTAA because the services were for use by Indian group entities, and the absence of a make available clause did not prevent taxation. Corporate guarantee fees were treated as income from other sources under Article 21, as the guarantee support was ancillary to shareholder support and connected with the Indian subsidiary. Matters relating to refund interest and TDS credit were remanded for verification and fresh consideration after hearing the assessee. Case-Laws Income Tax Tue, 29 Aug 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=442485