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Income Tax - Highlights / Catch Notes

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Income accrued in India - Fee for Technical Services [FTS] - ...


Income from marketing and sales in India not considered technical service fees under Article 12(4)(b) of Indo-Singapore DTAA.

October 9, 2023

Case Laws     Income Tax     AT

Income accrued in India - Fee for Technical Services [FTS] - 'make available’ - the marketing and sales services, operations and standardization services do not satisfy the “make available” clause as per article 12(4)(b) of Indo Singapore DTAA and, therefore, the amounts are attributable for these services cannot be held to be fees for technical services. - AT

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