2008 (11) TMI 9 - AUTHORITY FOR ADVANCE RULINGS

Applicant, a company in India is subsidiary of ITM, UK - business of rendering testing and inspection services to its Indian and overseas clients - it is not possible to hold that all the services rendered do not fall under FTS (Royalties & Fee for Technical Services) & that the entirety of service fee charged to the applicant does not constitute the income of ITM, UK under Article 13 of the Treaty - applicant is directed to approach the competent authority to determine the issue of TDS