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1. Income accrued In India - 'Royalty' or 'Fees for Technical Services' under Section 9(l)(vi) and 9(l)(vii) - the payment made by SCB to assessee- company does not fall...

2. Income taxable in India - payments received from its India customers on account of Centralized Services - Fee for Technical Services - Fee for included services - The...

3. 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...

4. TDS Liablity - fees for technical services - payment of rArchitectural services and Interior designing and Architectural services - Since, we have held that the payments...

5. Fees for technical services (FTS) - India France DTAA - claiming the benefit of the restricted definition under India USA DTAA - Since the assessee has been found not to...

6. Income chargeable to tax as FIS in India - Fee for included service - The e-publishing work in the nature of editorial services comprising of page composition, language...

7. Income accrued in India - Fee for Technical Services [FTS] - 'make available’ - the marketing and sales services, operations and standardization services do not satisfy...

8. Income deemed to accrue or arise in India - receipts of subscription fees - The ITAT had found that it did not involve the transfer of copyright or the provision of...

9. Fees for technical services’ (‘FTS’) - The conclusion drawn by the AO is not proper because the training simply advances the skill of the recipient-employees but falls...

10. Corporate guarantee - fee for technical services (FTS) under article 13 of the India France DTAA and section 9(1)(vii) - services of corporate guarantee by the assessee...

11. Taxability of Fees for technical services (FTS) - In Article–13(4)(c) of the India–UK tax treaty the words “or consists of the development and transfer of a technical...

12. TDS u/s 195 - professional services - Fees for Technical Services (FTS) - the definition of “Fees for Technical Services” has to be given a restrictive meaning similar...

13. Income accrued in India - testing and other services - exception curved out to Article 12(5) of the India-Finland DTAA that when the fees is paid for technical services...

14. Fees for Technical Services - Reimbursement of salary and other related costs - the salaries of such seconded employees were deposited in their overseas bank accounts,...

15. Taxability as Fee for Included Service (FIS) u/A 12 of India-USA DTAA - As per Example 7 of the Memorandum of Understanding to India-USA DTAA, a receipt cannot be...