Jain Shrimal & Co.

September 2022

Is Form 10F mandatory if TRC contains all details – JSCO | SITG

Saturday International Tax Gyan!! #taxmadeeasy #taxinpic Recently we have seen that Form 10F needs to be filed online on e-filing portal for which the Non-resident will have to take PAN and DSC in India. Today we shall discuss the situations wherein Form 10F will not be mandatory if various conditions are fulfilled and will check on sample …

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If the “make available” clause is not satisfied income cannot be taxed as FTS – JSCO | SITG

Saturday International Tax Gyan!! #taxmadeeasy #taxinpic Enrichment of service recipient/Addition to his capabilities sans transfer of skill/technology will not satisfy “make available” clause, and hence is not taxable as FTS under DTAA (NTT Asia Pacific Holdings Pte Ltd. V/s Assistant Commissioner of Income-tax, Circle 2(1)(2)[2022] 141 taxmann.com 137 (Mumbai – Trib.))

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