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Income Tax - Highlights / Catch Notes

Home Highlights December 2020 Year 2020 This

Addition u/s. 40(a)(ia) r.w. 195 - The rendition of services for ...

Income Tax

December 8, 2020

Addition u/s. 40(a)(ia) r.w. 195 - The rendition of services for earning commission cannot be of such a nature that there is a transfer of technology, in the sense it is required to fulfil the 'make available' clause in the Indo UK DTAA. - even if the commission income in the hands of the recipient is taxable under the provisions of Section 9, the provisions of the Indo UK DTAA will come to the rescue of the assessee. - AT

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