2024 (1) TMI 560

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..... 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 - as per HC [ 2023 (3) TMI 422 - KARNATAKA HIGH COURT] services received by the assessee cannot be considered as Royalty or Fee for included services to deduct TDS - HELD THAT:- Delay in filing the special leave petitions is con .....

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