https://www.taxtmi.com/caselaws?id=448161 Dispute concerns whether cross-border payments for marketing services to a US company constitute Fee for Technical Services (FTS) attractable to withholding tax under TDS provisions and IndiaUSA DTAA, given the foreign entity lacked a permanent establishment in India. The High Court had held the services could not be characterised as royalty or FTS to mandate TDS. The Supreme Court condoned delay but declined to disturb that approach, following prior Supreme Court precedent, and dismissed the special leave petition, leaving the High Court position intact. en-us Fri, 08 Dec 2023 00:00:00 +0530 Fri, 29 May 2026 11:15:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=448161 Dispute concerns whether cross-border payments for marketing services to a US company constitute Fee for Technical Services (FTS) attractable to withholding tax under TDS provisions and IndiaUSA DTAA, given the foreign entity lacked a permanent establishment in India. The High Court had held the services could not be characterised as royalty or FTS to mandate TDS. The Supreme Court condoned delay but declined to disturb that approach, following prior Supreme Court precedent, and dismissed the special leave petition, leaving the High Court position intact. Case-Laws Income Tax Fri, 08 Dec 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=448161