2023 (11) TMI 594 - SCH - Income Tax

TDS u/s 195 - payments made by the assessee for marketing services to the US Company as taxable in India as FTS Fee for Technical Services - US Company does not have any permanent establishment in India - order under Section 201(1) 201(1A) - India- USA DTAA - HC held that 2023 (3) TMI 422 - KARNATAKA HIGH COURT scope of the work is to generate customer leads using/subscribing customer data base, market research, analysis, and online research data and rightly held that the service provider has not made available any technical knowledge, experience, knowhow, process or develop and transfer technical plan or technical design - HELD THAT - UPON hearing the counsel the Court made the following. Delay in filing the special leave petition is condoned. The special leave petition is dismissed. Pending application(s), if any, shall also stand disposed of.