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2024 (1) TMI 616 - 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 - Taxation on contracting state - Revenue’s case is payments made to the US Company for marketing services take the character of FTS and chargeable to tax in India - as decided by HC [2023 (3) TMI 422 - KARNATAKA HIGH COURT] operations were not in India and expenses towards maintenance and repairs payments were made for the purpose of earning outside India - HELD THAT:- Following the order passed in M/s AD2PRO Media Solutions Pvt. Ltd [2024 (1) TMI 560 - SC ORDER] this special leave petition also stands dismissed.
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