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TaxBuzz | Taxability of Receipts as FTS – Illuminating Findings on ‘Make Available’ & ‘Source Rule’ September 16, 2024
Published in: TaxBuzz
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We are pleased to share with you a copy of our in-house publication – “TaxBuzz”.
In this edition, we have analysed the recent judgment in International Management Group (UK) Ltd, wherein the Delhi High Court has examined the taxability of receipts of a UK resident taxpayer towards advisory and managerial services as Fees for Technical Services (“FTS”).
Pertinent findings have been recorded by the High Court on the ‘source rule’ contained in section 9(1)(vii) of the Income-tax Act, 1961 as well as on the satisfaction of ‘make available’ clause for taxability of receipts as FTS under the India-UK DTAA. The judgment also expounds the law on taxability of receipts remaining after attribution to Permanent Establishment in India.
We trust that you will find our TaxBuzz useful and look forward to receiving your valuable feedback.
For any clarifications, please write to:
Mr. Neeraj Jain
Senior Partner
[email protected]
Mr. Aditya Vohra
Associate Partner
[email protected]
Mr. Arpit Goyal
Senior Associate
[email protected]
