Jain Shrimal & Co.

December 2024

Warehouse payment will not be considered as payment for FTS under section 9(1)(vii)

Saturday International Tax Gyan!! (SITG – 236) #taxmadeeasy #taxinpic Avtec Ltd. vs ACIT [2024] 168 taxmann.com 692 (Delhi – Trib.) [29.11.2024] “Payments for warehousing services are logistical in nature and do not qualify as ‘Fees for Technical Services’ (FTS) under Section 9(1)(vii) of the Income Tax Act or DTAA, as they do not ‘make available’ …

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FTC credit not dependent on filing of tax return in foreign jurisdiction

Saturday International Tax Gyan!! (SITG – 235) #taxmadeeasy #taxinpic Amarchand Mangladas & Suresh A Shroff & Co. vs ACIT [2024] ITA No.852/M/2024 [30-09-2024] Filing tax return is not mandatory for FTC eligibility as taxes withheld abroad qualifies as taxes paid and allowed full FTC to prevent double taxation, in line with DTAA provisions and established …

FTC credit not dependent on filing of tax return in foreign jurisdiction Read More »

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