TDS u/s 195 - Outsourcing charges payable treated as 'fees for ...

Income Tax

May 14, 2022

TDS u/s 195 - Outsourcing charges payable treated as 'fees for technical services' - These individuals are employees of iRunway Inc. and fulfill the criteria of the relevant US statutory requirements to be able to access the protective information. None of these individuals are employees of the assessee as incorrectly alleged by the revenue. AO failed to appreciate that owing to the legal restrictions in the US, iRunway Inc. or its employees did not have an opportunity or any occasion to 'make available' any technical knowledge to the assessee or its employees while rendering services. - AT

View Source

← Previous Next →

TDS u/s 195 - Outsourcing charges payable treated as 'fees for ...

Income Tax

May 14, 2022

You may also like:

TDS liability u/s 195 - Income accrued in India - fees for technical services - thus Solutions provided by the Applicant without human intervention cannot be treated as...

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...

TDS u/s 195 - Disallowance of management fee paid by invoking the provisions of section 40(a)(i) - whether payment of management fees cannot be regarded as fees for...

Disallowance u/s 40(a)(ia) - failure to deduct TDS u/s 195 - in view of Protocol between India and Spain, the restrictive meaning of ‘Fee for Technical Services’...

TDS u/s 195 - Taxability of management fees paid by the appellant to UST Global - The remuneration received by the US Company for the services offered to the Indian...

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...

TDS on Arrangers Fees - whether fee for technical services (FTS) or commission - u/s 195 r.w.s. 40(a)(i) -The amount paid by the assessee to the non-residents...

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...

TDS - wheeling charges and transmission charges are neither contractual payments nor fee for technical services u/s. 194C or 194J - No TDS required - AT

TDS liability on wheeling charges - "wheeling charges" did not amount to "fees for technical services" within the meaning of Section 194J - No tds liability - SC

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...

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...

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...

TDS u/s 195 - fees for technical services - Since, the payments are made prior to the amendment, it is impossible for the assessee to perform impossible things and...

TDS u/s 195 - whether the payments made by the assessee to its foreign subsidiaries would fall under the ambit of ‘fees for technical services’ as per the DTAA - Held No - AT

Quick Updates: