<?xml version="1.0" encoding="UTF-8"?>
<?xml-stylesheet type="text/xsl" href="https://www.taxtmi.com/rss_sitemap/rss_feed_blog.xsl?v=1750492856"?>
<rss version="2.0" xmlns:atom="http://www.w3.org/2005/Atom">
  <channel>
    <title>Beneficial domestic tax rate for FTS prevails where RBI automatic-route remittance satisfies approval conditions under treaty</title>
    <link>https://www.taxtmi.com/highlights?id=101060</link>
    <description>For fees for technical services, the Tribunal held that the domestic rate under section 115A(1)(b) applied because the remittance was within the RBI automatic route and no separate approval was required on the facts. It construed the approval condition practically, not as a barrier that would make compliance impossible, and applied section 90(2) to permit the assessee to use the more beneficial 10% domestic rate instead of the treaty rate. The education cess ground was dismissed as already settled against the assessee, and interest was treated as consequential.</description>
    <language>en-us</language>
    <pubDate>Wed, 24 Jun 2026 07:08:06 +0530</pubDate>
    <lastBuildDate>Wed, 24 Jun 2026 07:08:09 +0530</lastBuildDate>
    <generator>TaxTMI RSS Generator</generator>
    <atom:link href="https://www.taxtmi.com/rss_feed_blog?id=908351" rel="self" type="application/rss+xml"/>
    <item>
      <title>Beneficial domestic tax rate for FTS prevails where RBI automatic-route remittance satisfies approval conditions under treaty</title>
      <link>https://www.taxtmi.com/highlights?id=101060</link>
      <description>For fees for technical services, the Tribunal held that the domestic rate under section 115A(1)(b) applied because the remittance was within the RBI automatic route and no separate approval was required on the facts. It construed the approval condition practically, not as a barrier that would make compliance impossible, and applied section 90(2) to permit the assessee to use the more beneficial 10% domestic rate instead of the treaty rate. The education cess ground was dismissed as already settled against the assessee, and interest was treated as consequential.</description>
      <category>Highlights</category>
      <law>Income Tax</law>
      <pubDate>Wed, 24 Jun 2026 07:08:06 +0530</pubDate>
      <guid isPermaLink="true">https://www.taxtmi.com/highlights?id=101060</guid>
    </item>
  </channel>
</rss>