This Tribunal decisions deals with issue as to whether rendering on call advisory services in the nature of troubleshooting, isolating problem and diagnosing related trouble and repair services remotely, will satisfy make available condition under India USA DTAA. FACTS Taxpayer is an Indian company and was engaged in the business of providing Annual Maintenance Contract […]
DIMENSION DATA ASIA PACIFIC PTE LTD. VS. DCIT [2018] 99 taxmann.com 270 (Mumbai); TS-604-ITAT-2018 (Mumbai Tribunal)
The Tribunal held that presence of employees is to be tested separately for each type of service for computing Service PE threshold. The Tribunal further held that application of beneficial provisions of the Act for one source of income and treaty for another source of income is permissible FACTS The Assessee is a private limited […]