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1. TDS u/s 195 - Scope of “make available” - The concept of make available which requires that fruits of services should remain unavailable to the service recipients in...

2. TDS u/s 195 - Disallowance u/s 40(a)(ia) - non-deduction of TDS on payment of management fees - It is not even the allegation of the revenue that the non-residents had...

3. Taxability as Fee for Included Service (FIS) u/A 12 of India-USA DTAA - As per Example 7 of the Memorandum of Understanding to India-USA DTAA, a receipt cannot be...

4. Fees for technical services (FTS) - Though, the departmental authorities have alleged that the make available condition stands satisfied, however, no material has been...

5. Income deemed to accrue or arise in India - receipts of subscription fees - The ITAT had found that it did not involve the transfer of copyright or the provision of...

6. IT support Services - DTAA with Belgium - payment of consideration would be regarded as FTS only if the twin test of rendering services and making technical knowledge...

7. Challenge AAR ruling - Income taxable in India or not? - TDS liability u/s 195 - whether payments to SIPCL for BSS under the Cost Contribution Arrangement ("CCA") - The...

8. Income accrued in India - fees for technical service (FTS) - Payment for certification of Diamonds - Mere rendering of services cannot be roped into FTS unless the...

9. Income deemed to accrue or arise in India - FTS under the India-USA DTAA - provision of information technology and other administrative services - In order to invoke...

10. Taxation of intermediary services - Intermediary services rendered by the appellant do not make available any technical knowledge, skill etc to BTIN and BTIN is not a...

11. TDS u/s 195 - Technical service would be FTS/FIS only when technical knowledge made available i.e. only if the twin test of rendering services and making technical...

12. TDS u/s 195 - remittance towards ‘group cost recharge’ to its associated enterprise(AE) in Singapore - impugned services rendered for which the payment was collected by...

13. TDS u/s 194C OR 194J - payee recipient had to merely issue its intellectual/technical skills without any physical work through employee or deploy assets - its...

14. Taxability of Fees for technical services (FTS) - In Article–13(4)(c) of the India–UK tax treaty the words “or consists of the development and transfer of a technical...

15. TDS u/s 194C OR 194J - services provided by highly skilled / technical professionals - supply and installation of HT and LT electrical installation equipments - services...