TMI BlogAssessee's Payment Not FTS: IPR Retained by Non-Resident Supplier; No Business Exploitation of Design & Development.Fees for technical services (FTS) - nature of payment - the assessee was not exploiting the D&D for business purposes, that IPR of the D&D were retained by the non resident supplier - disputed amount cannot be considered as FTS - AT ..... X X X X Extracts X X X X X X X X Extracts X X X X
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