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 […]
APPLICABILITY OF TDS ON REPAIR AND MAINTENANCE SERVICES
As per the provisions of Section 9(1)(vii) of the Act payment by resident to non-resident is liable to tax in India if the payment is towards ‘Fees for Technical Services’ (“FTS”). Explanation 2 under Section 9(1)(vii) defines the term FTS. FTS is defined to include consideration for services of managerial, technical or consultancy nature, including […]