excluded from taxation.
6.7. On taxability of fee for technical services (FTS), he submitted that the
assessee committed an error by filing his return ... income in as much as,
the income from FTS was not disclosed in the return of income. He
submitted that the entire FTS received
hands of the recipients both as Royalty as well as FTS and therefore, the
assessee was liable to deduct TDS and since, the assessee ... liable to tax or not in the hands of the
recipients as FTS , as per Para 45, the tribunal remanded the matter back
will hereinafter be referred to as "fees for technical services" (FTS).
Asst. yr. 1994-95:
9. The assessee filed its return of income ... between the assessee and the Department already referred to. The assessee received FTS for supervising the installation of the machinery and equipment supplied
purview of Royalty/ Fees for Technical
Services (hereinafter, referred to as „FTS‟) and is liable to be taxed under
section 44DA instead of section 44BB ... once a particular receipt of
income takes on the character of Royalty/FTS as defined in section 9(1) (vi) /
9(1) (vii) , it cannot
Delhi (6 years) yearly Rs.350
(1350 sq.fts. escalation (11.04.2010 to
Mezzanine from 10.04.2011)
Floor) 11.04.2010)
2. 13,Community ... Friends Colony, 22.10.2016 (23.10.2007
New Delhi (850 (9 years) to
sq.fts. Ground 22.10.2010)
Floor)
18. Having seen the evidence led by the plaintiffs
residential building having plinth area 278.7 Sq. metres, equivalent to 3000 sq.fts., and above itself gives the meaning of 'luxury' contemplated ... residential building completed after 1.4.1999 having a plinth area of 3000 sq. fts., and above is treated as an item of 'luxury
Taraf for Development & Investment LLC.
is not fees for Technical Services (FTS) both under section 9(1)(vii) as well as
the relevant article ... OCTG Venezuelen Distributor CA
(x) Narfoamkarjit
is not fees for Technical Services (FTS) both under section 9(1)(vii) as well as the
relevant article
such
reimbursement of demurrage and shipment costs as fees for
technical services (FTS') taxable under section ... held
the amount to be in the nature of FTS and hence liable to tax in India
assessee falls within the meaning of fee for
Technical services(FTS) as per explanation 2 to Sec.9(1)(vii) of Income
Tax Act, hence ... thought and dealing with India Thailand tax treaty, which does not have
FTS clause, rejected the claim of the revenue that even though the Thai
consultancy services and hence should not quality as Fees for Technical
Services (FTS) u/s 9(1)(vii) of the Act. Accordingly, the remittances would ... taxable as Royalty / FTS under the Act. Further since all the operations of Payee are
carried out outside India, in accordance with clause
