Tax Management India. Com
Law and Practice  :  Digital eBook
Research is most exciting & rewarding
  TMI - Tax Management India. Com
Follow us:
  Facebook   Twitter   Linkedin   Telegram
Income Tax - Highlights / Catch Notes

Home Highlights April 2018 Year 2018 This

Fees for technical services (FTS) - nature of payment - the ...


Assessee's Payment Not FTS: IPR Retained by Non-Resident Supplier; No Business Exploitation of Design & Development.

April 2, 2018

Case Laws     Income Tax     AT

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

View Source

 


 

You may also like:

  1. Receipt of Fees for Technical Services (FTS) - there is no dispute that the payment made was in the nature of FTS and there is no article in DTAA for taxing the FTS...

  2. Disallowance of claim of commission payment - Liability to deduct TDS for making payment to Non-Residents - withholding tax - where payment of commission has been made...

  3. Income accrues or arises in India - services to MTR foods Private Limited who is located outside India - Secondment charges paid in respect of the professional services...

  4. TDS u/s 195 - payments by resident Indian end-user to non-resident computer software manufacturers/suppliers - payment for software licenses not royalty under Article 12...

  5. TDS u/s 195 - payment made to non-resident marketing partner - the services rendered by marketing partner is in the nature of FTS, the assessee ought to have deducted...

  6. TDS liability u/s 195 - payments made to the non-residents / father of the non-resident - The entire payment was made to the resident Indian who is also the father of...

  7. Rate of TDS - Non-availability of PAN - Benefit of treaty - in case of payments made to non-residents, the assessee was entitled to deduct taxes at source at the rates...

  8. Disallowance of Professional fees paid to non-residents - Non deduction of TDS u/s 195 - the assessee cannot be expected to deduct TDS on payment made to non-residents...

  9. TDS u/s 195 - royalty payments or not - Consideration for advertisement is paid to the overseas bank account of Non-resident - the payments made by the assessee the...

  10. Liability to pay interest u/s 234B - In the light of legal position as it existed for the relevant Assessment Years prior to insertion of proviso to Section 209(1) of...

  11. No doubt, if the person (payer) who had to make payments to the non-resident had defaulted in deducting the tax at source from such payments, the non- resident is not...

  12. TDS u/s 195 - amounts paid by the assessee to the non-resident computer software manufacturers / suppliers as consideration for the resale / use of computer software, is...

  13. TDS u/s 195 - payments made to non-resident - The amounts paid by resident Indian endusers/ distributors to non-resident computer software manufacturers/suppliers, as...

  14. Disallowance of expenses u/s.40(a)(ia) - Non deduction of TDS u/s 195 - at the time of payment made by the assessee to non-residents, there was an ambiguity in the...

  15. Non deduction of TDS on payment to non-resident - disallowance u/s 40(a)(i) - a similar payment to a resident does not result in disallowance in the event of non...

 

Quick Updates:Latest Updates