Indo-Italian DTAA Payments Classified as Fees for Technical Services, Disallowed u/s 40(a)(ia) of Income Tax Act.

Indo-Italian DTAA. - TDS on payment made to non residents - Nature of payment - overseas commission or fee for technical services (FTS) - systematic research- Held as FTS - disallowance confirmed u/s 40(a)(ia) - AT .....

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