Tax Management India. Com
Law and Practice  :  Digital eBook
Research is most exciting & rewarding
  TMI - Tax Management India. Com
Follow us:
  Facebook   Twitter   Linkedin   Telegram
Income Tax - Highlights / Catch Notes

Home Highlights May 2023 Year 2023 This

Addition on account of services rendered by the assessee to its ...

May 31, 2023

Case Laws     Income Tax     AT

Addition on account of services rendered by the assessee to its AE in India - whether FTS under the provisions of Article 13(4)(c) of the India-UK DTAA? - the assistance, support or advice provided by the assessee to BTPL shall not per se be considered to make technology available since the assessee did not make available any technical knowledge, experience or skill to BTPL by way of rendering the above support services to BTPL. Article 13(4) of the India–UK DTAA does not apply to the assessee’s case and hence the consideration could not be included in FTS. - AT

View Source

 


 

You may also like:

  1. The court examined whether the receipts from services rendered by IMG to BCCI for IPL were taxable as Fees for Technical Services (FTS) under Article 13 of the India-UK...

  2. Fees for technical services (FTS) - India France DTAA - claiming the benefit of the restricted definition under India USA DTAA - Since the assessee has been found not to...

  3. Fees for Technical Services (FTS) - The AO himself has stated that some of the services are of the nature of FTS. Thus, AO clearly admits that all the services rendered...

  4. Income accrued or deemed to accrue in India - As the design services were inextricably connected with setting up of the plant and were rendered through this PE, the...

  5. Income accrues or arises in India - services to MTR foods Private Limited who is located outside India - Secondment charges paid in respect of the professional services...

  6. PE in India - India-Spain DTAA - business profit carried out through PE - Services rendered from outside India - there is no Permanent Establishments during the relevant...

  7. Income deemed to accrue or arise in India - PE in India - employees of the assessee were present in India for rendering services for a period aggregating to only 13 days...

  8. Income accrued or deemend to accrue in India - Fees for technical services' under Article 12(5)(a) of the India-Netherlands tax treaty - as providing of access to CRS,...

  9. 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...

  10. Income deemed to accrue or arise in India - salary received by the assessee in India for the services rendered in USA - though the provision under section 5(2)(a) of the...

  11. Income accrued in India - Amount accrued to the Assessee from another group company in India on account of management support costs - FTS under the India- Singapore DTAA...

  12. The assessee, a foreign company, earned network transportation fees from its Indian associated enterprise (AE), Damco India Private Limited (DIPL). The Assessing Officer...

  13. Article 13 of the DTAC between India and France - Services rendered on marketing, strategy and training to optimize sales techniques come within the purview of...

  14. TDS u/s 195 - Taxability of income in India - PE in India - taxation of offshore supplies - Taxation of Fee for Technical Services (FTS) in the absence of FTS article...

  15. 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...

 

Quick Updates:Latest Updates