Income accrued in India - TDS u/s 195 - fees for included ...

Receipts from PGCIL not 'fees for included services' under India-US DTAA Articles 12(4)(a) & 12(4)(b).

March 21, 2022

Case Laws Income Tax AT

Income accrued in India - TDS u/s 195 - fees for included services (FTS) - USA DTAA - the PGCIL would not apply technology on its own. It would continue to depend on the assessee for provision of software and hardware maintenance and support services in the future. Thus, keeping in view of the facts and circumstances of the case, receipts from PGCIL do not qualify as 'fees for included services' under articles 12(4)(a) and 12(4)(b) of India - US DTAA. - AT

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Income accrued in India - TDS u/s 195 - fees for included ...

Receipts from PGCIL not 'fees for included services' under India-US DTAA Articles 12(4)(a) & 12(4)(b).

March 21, 2022

Case Laws Income Tax AT

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