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2009 (11) TMI 29 - AAR - Income TaxTechnology Assessment and Commercialization” (”ATAC”) – assisting DRDO laboratories in identification and business development of competitive global technologies from its inventory of existing defence-related innovations - award of certain work to to perform certain work and services for the “IC2-FICCI-DRDO Innovation programme” in USA – Appliability of DTA – Applicability of with holding tax (TDS) – held that - Evaluating the potential of technologies after interaction with the experts and passing on the results of its interaction or furnishing relevant informations which are mostly in public domain in order to enable DRDO to find potential customers for the concerned technologies do not, in our view, fall within the scope of services contemplated by paragraph 4 of Art.12 of the DTAA - Provision of DTAA applicable – Income of UT is not taxable in India – TDS is not required to be deducted
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