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2024 (1) TMI 560 - SCH - Income TaxTDS u/s 195 - payments made by the assessee for marketing services to the US Company as taxable in India as FTS [Fee for Technical Services] - US Company does not have any permanent establishment in India - order under Section 201(1) & 201(1A) - India- USA DTAA - as per HC [2023 (3) TMI 422 - KARNATAKA HIGH COURT] services received by the assessee cannot be considered as ‘Royalty’ or ‘Fee’ for included services to deduct TDS - HELD THAT:- Delay in filing the special leave petitions is condoned. We are not inclined to interfere in the matter. Following the order [2023 (11) TMI 594 - SC ORDER], this special leave petition is also dismissed.
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