technical expertise

AAR on taxability of an American Institute for rendering certain work and service to FICCI-DRDO Innovation programme

The services/activities provided by the American Institute to DRDO pursuant to the agreement entered into between FICCI and the American Institute do not fall within the purview of Article 12(4)(b) of the Indo-US DTAA and the payments received by the Institute under the agreement are not liable to be taxed as fees for technical services under the domestic law; consequently, FICCI is not required to deduct tax under section 195 for payments made by it to the American Inst..
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Even a Contractor is a “Developer” for purposes of s. 80-IA(4): ITAT Jaipur

Om Metals Infraprojects vs. CIT (ITAT Jaipur) Where the assessee entered into an agreement with the Vidharbha Irrigation department for supply, erection and installation of dam gates and the question arose whether it was “developing an infrastructural facility” so as to be eligible for deduction u/s 80-IA (4) or it was a mere contractor, HELD:
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