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Income Tax - Highlights / Catch Notes

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Taxability of foreign income in India - business connection’ in ...

Case Laws     Income Tax

July 4, 2023

Taxability of foreign income in India - business connection’ in India or not? - subscription services - ITAT came to the factual finding that the arrangement between assessee and the subscribers was for the provision of services for standard facility and not for “rendering of any technical, managerial or consultancy services” as provided in section 9(1)(vii) r/w Explanation 2 of the Act - Subscription fees not to be treated in the nature of fees for technical services (FTS) - Revenue appeal dismissed - HC

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