2024 (1) TMI 616

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..... ny does not have any permanent establishment in India - order under Section 201(1) 201(1A) - India- USA DTAA - Taxation on contracting state - Revenue s case is payments made to the US Company for marketing services take the character of FTS and chargeable to tax in India - as decided by HC [ 2023 (3) TMI 422 - KARNATAKA HIGH COURT] operations were not in India and expenses towards maintenance .....

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