India-
USA, DTAA to constitute Fees for Technical Services (FTS). It was further
contended that the services rendered are not in relation to development ... India-USA, DTAA or that the services rendered would not
constitute FTS under Article 12(4)(b) of the India-USA, DTAA
aforesaid
payments consisted payment in the nature fees for technical services
rendered (FTS) which is chargeable to tax in India in the case ... view that the relocation expenses were in the
nature of FTS and he observed in this regard as follows
employee, treating the same amount as 'fees for technical
services' (FTS) remitted to the parent company in USA does not arise.
He also ... held that the AO taxed the FTS at the rate of 10% + Surcharge
and Education Cess which put together works out to only
M/S. Abbey Business Services ... vs Assessee on 7 July, 2012
IN THE INCOME TAX
same country, but, pursuant to separate
agreements.
C. Income from royalty & FTS from same company :
Extending the above logic further, there could be instances ... pertain to the same head of income.
D. Income from royalty & FTS for two different periods.
For the reasons already detailed, income derived from
appellant to ETC were in the nature of fees for
technical services (FTS) u/s 9(1)(vii) of the Act.
3 ITA No.1490
Kadakola to link with 66 KV 73,974
FTS-SFC M2 line near Alanahally
TOTAL 18,44,463
(iii) Major works Division, Belgaum :
Sl. Nature
resident company are nothing but fees for technical
services (FTS) as defined in explanation
resident company are nothing but fees for technical
services (FTS) as defined in explanation
India Singapore Treaty 'fees for technical
services' (FTS) can be brought to tax only if such services (make
available) technical knowledge, experience, skills ... then the payment can be said to be
a payment for 'FTS'. The assessee submitted that the Singapore
company did not make available
