2016 (6) TMI 1365 - SCH - Income Tax

Fees for technical services received - computation of period of stay - whether taxable by reason of article 12(2) of the DTAA with Japan? - HELD THAT - The essential question is whether Article 12(2) or 12(5) of the Agreement which is applicable in these cases. In the facts of these cases we are not inclined to go into this aspect. The special leave petitions are accordingly dismissed

Summary

The Supreme Court of India dismissed the special leave petitions, with the question of law kept open. Delay was condoned, and the court did not delve into the applicability of Article 12(2) or 12(5) of the Agreement in the cases. Pending application(s) were disposed of.