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1. TDS u/s 195 - FTS in DTAA with USA - In view of Section 90(2) and clause 4(b) of Article 12 of the Treaty, the provisions of this Act would stand applicable only where...

2. TDS u/s 195 - Scope of “make available” - The concept of make available which requires that fruits of services should remain unavailable to the service recipients in...

3. TDS u/s 195 - Disallowance u/s 40(a)(ia) - non-deduction of TDS on payment of management fees - It is not even the allegation of the revenue that the non-residents had...

4. Challenge AAR ruling - Income taxable in India or not? - TDS liability u/s 195 - whether payments to SIPCL for BSS under the Cost Contribution Arrangement ("CCA") - The...

5. IT support Services - DTAA with Belgium - payment of consideration would be regarded as FTS only if the twin test of rendering services and making technical knowledge...

6. Fees for technical services (FTS) - Though, the departmental authorities have alleged that the make available condition stands satisfied, however, no material has been...

7. TDS u/s 195 - disallowance u/s. 40(a)(i) for non deduction of TDS on payment to non-resident which is in nature of FTS(Fee for Technical Service) - beneficial provisions...

8. 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...

9. 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...

10. TDS u/s 195 - remittances made to CGTM, France - FTS - there was no question of deduction of TDS on the payment made to CGTM, France for the service rendered by them to...

11. Income deemed to accrue or arise in India - Fees for Technical Services (FTS)/Fees for Included Services (FIS) - Assessee is not the ultimate beneficiary of the sum in...

12. TDS u/s 195 - the Singapore company as a Consultant has made available to the assessee company technical knowledge in the form of expertise in the operation of its...

13. 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...

14. TDS u/s 195 - Sales commission paid to foreign company - non deduction of TDS - addition u/s 40(a)(i) - ITAT upheld the CIT(A)'s decision, noting that services rendered...

15. Income deemed to accrue or arise in India - MOU to the India US DTAA elaborates on the concept of "make available" - Merely providing commercial information through a...