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 July 2023 Year 2023 This

Fees for technical services (FTS) - Though, the departmental ...

Case Laws     Income Tax

July 5, 2023

Fees for technical services (FTS) - Though, the departmental authorities have alleged that the make available condition stands satisfied, however, no material has been brought on record to support such finding. - The burden is entirely on the Revenue to prove that rendition of services by the assessee has made available technical knowledge, knowhow, skill etc. to the service recipient so as to enable the service recipient to utilize such technical knowledge, knowhow, skill etc. independently in future without the aid and assistance of the assessee. - AT

View Source

 


 

You may also like:

  1. Income accrued in India - Fee for Technical Services [FTS] - 'make available’ - the marketing and sales services, operations and standardization services do not satisfy...

  2. Income deemed to accrue or arise in India - Fee for Technical Services (FTS)/ Fee for Included Services (FIS) - the services provided by the assessee under the marketing...

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

  4. Corporate guarantee - fee for technical services (FTS) under article 13 of the India France DTAA and section 9(1)(vii) - services of corporate guarantee by the assessee...

  5. TDS u/s 195 - professional services - Fees for Technical Services (FTS) - the definition of “Fees for Technical Services” has to be given a restrictive meaning similar...

  6. The ITAT considered the taxability of income in India as Fees for Included Service (FIS) or Fees for Technical Services (FTS) received by a non-resident corporate entity...

  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. The Appellate Tribunal addressed the taxability of payments as Fee for Technical Services (FTS) u/s 195. The Assessing Officer (AO) found the services provided by the...

  9. 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...

  10. The assessee received amounts from Indian customers for supplying software updates, patches, and on-call support services. The issue pertained to taxability of these...

  11. The key points in the legal document are: Software licensing amounts do not qualify as Fees for Included Services under Article 12(4)(b) of the India-US DTAA, as the...

  12. Taxability of income in India - receipts from services rendered to Indian entities - Fee for Technical Services (FTS) - Despite the assessee's contention that the...

  13. 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...

  14. Taxability of Fees for technical services (FTS) - In Article–13(4)(c) of the India–UK tax treaty the words “or consists of the development and transfer of a technical...

  15. Income deemed to accrue or arise in India - Fees for Technical Services (FTS)/Fees for Included Services (FIS) - Assessee is not the ultimate beneficiary of the sum in...

 

Quick Updates:Latest Updates