Home Case Index All Cases Income Tax Income Tax + SCH Income Tax - 2023 (6) TMI SCH This
Forgot password New User/ Regiser ⇒ Register to get Live Demo
2023 (6) TMI 981 - SCH - Income TaxIncome deemed to accrue or arise in India - India - USA DTAA - FTS OR FIS - payments received by the Assessee from its Indian Customers on account of Centralized Services viz. sales and marketing, loyalty programs, reservation service, technological service, operational services and training programs/human resources do not constitute ‘Fee for Technical Services’ u/s 9(l)(vii) or 'Fee for included services’ as defined under Articles 12(4) (a) of the Indo-US DTAA - HELD THAT:- Delay condoned. Leave granted. Issue notice on the appeal, returnable in four weeks.
|