2023 (6) TMI 981 - SCH - Income Tax

Income deemed to accrue or arise in India - India - USA DTAA - FTS OR FIS - payments received by the Assessee from its Indian Customers on account of Centralized Services viz. sales and marketing, loyalty programs, reservation service, technological service, operational services and training programs/human resources do not constitute Fee for Technical Services u/s 9(l)(vii) or 'Fee for included services as defined under Articles 12(4) (a) of the Indo-US DTAA - HELD THAT - Delay condoned. Leave granted. Issue notice on the appeal, returnable in four weeks.

Summary

The Supreme Court of India in the case of 2023 (6) TMI 981 - SC granted leave to appeal after condoning delay. Notice issued on the appeal returnable in four weeks. Justices S. Ravindra Bhat and Dipankar Datta presided over the case. Petitioner represented by Mr. Balbir Singh, A.S.G., and other advocates.