TDS u/s 195 - whether the payments made by the assessee to its ...

Foreign Subsidiary Payments Not 'Fees for Technical Services' Under DTAA.

July 14, 2016

Case Laws Income Tax AT

TDS u/s 195 - whether the payments made by the assessee to its foreign subsidiaries would fall under the ambit of ‘fees for technical services’ as per the DTAA - Held No - AT

View Source

← Previous Next →

TDS u/s 195 - whether the payments made by the assessee to its ...

Foreign Subsidiary Payments Not 'Fees for Technical Services' Under DTAA.

July 14, 2016

Case Laws Income Tax AT

You may also like:

Income taxable in India - payments received from its India customers on account of Centralized Services - Fee for Technical Services - Fee for included services - The...

Corporate guarantee - fee for technical services (FTS) under article 13 of the India France DTAA and section 9(1)(vii) - services of corporate guarantee by the assessee...

Taxability of receipts as 'fees for included services' under the India-USA Double Taxation Avoidance Agreement (DTAA). The key points are: The Assessing Officer (AO)...

TDS u/s 195 - Disallowance of management fee paid by invoking the provisions of section 40(a)(i) - whether payment of management fees cannot be regarded as fees for...

TDS on certain foreign payments - reimbursements of expenses - independent professional service - The case involves a dispute over the classification of services...

TDS Liablity - fees for technical services - payment of rArchitectural services and Interior designing and Architectural services - Since, we have held that the payments...

TDS u/s 195 not deducted on payment to Everest Global Inc. for software training services as source of income located outside India and payment made for services outside...

TDS u/s 195 - professional services - Fees for Technical Services (FTS) - the definition of “Fees for Technical Services” has to be given a restrictive meaning similar...

Income accrued In India - 'Royalty' or 'Fees for Technical Services' under Section 9(l)(vi) and 9(l)(vii) - the payment made by SCB to assessee- company does not fall...

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...

Transfer of ESOP/ESPP/RSU by foreign holding company to employees of domestic subsidiary company does not attract GST where no additional fee, markup or commission is...

The summary relates to the taxability of management service fees received by a foreign entity from an Indian entity under the India-Netherlands Double Taxation Avoidance...

Income deemed to accrue or arise in India - amounts received by the assessee from its Indian subsidiary towards IT and SAP charges - the services rendered under IT and...

The assessee received amounts from Indian customers for supplying software updates, patches, and on-call support services. The issue pertained to taxability of these...

ITAT adjudicated a tax dispute concerning technical services fees under Section 9(1)(vii) of the Income Tax Act and India-Netherlands Tax Treaty. The tribunal determined...

Quick Updates: