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1. TDS u/s 195 - Scope of “make available” - The concept of make available which requires that fruits of services should remain unavailable to the service recipients in...

2. TDS u/s 195 - Disallowance u/s 40(a)(ia) - non-deduction of TDS on payment of management fees - It is not even the allegation of the revenue that the non-residents had...

3. Taxability as Fee for Included Service (FIS) u/A 12 of India-USA DTAA - As per Example 7 of the Memorandum of Understanding to India-USA DTAA, a receipt cannot be...

4. Taxability of receipts as 'fees for included services' under the India-USA Double Taxation Avoidance Agreement (DTAA). The key points are: The Assessing Officer (AO)...

5. Fees for technical services (FTS) - Though, the departmental authorities have alleged that the make available condition stands satisfied, however, no material has been...

6. The Income Tax Appellate Tribunal (ITAT) held that the consultancy services rendered by the assessee, such as organizational strategy, talent acquisition, rewards and...

7. Income deemed to accrue or arise in India - receipts of subscription fees - The ITAT had found that it did not involve the transfer of copyright or the provision of...

8. IT support Services - DTAA with Belgium - payment of consideration would be regarded as FTS only if the twin test of rendering services and making technical knowledge...

9. The assessee, incorporated under Canadian laws, rendered pre-clinical laboratory services to Indian customers in the pharmaceutical, medical device, and biotechnology...

10. Challenge AAR ruling - Income taxable in India or not? - TDS liability u/s 195 - whether payments to SIPCL for BSS under the Cost Contribution Arrangement ("CCA") - The...

11. Income accrued in India - fees for technical service (FTS) - Payment for certification of Diamonds - Mere rendering of services cannot be roped into FTS unless the...

12. Income deemed to accrue or arise in India - FTS under the India-USA DTAA - provision of information technology and other administrative services - In order to invoke...

13. Taxation of intermediary services - Intermediary services rendered by the appellant do not make available any technical knowledge, skill etc to BTIN and BTIN is not a...

14. Income deemed to accrue or arise in India - treatment of "Commission income" and receipts from "Subscription fee" - Assessee in publishing business receiving...

15. TDS u/s 195 - Technical service would be FTS/FIS only when technical knowledge made available i.e. only if the twin test of rendering services and making technical...