Taxability of Architectural services provided by a limited partnership under the provisions of DTAA with USA
Advertisement
Advertisement
Skip to content
Follow Us on
Books Submit Post Subscription
Advertisement
TOP STORIES
Income Tax Fresh U/s 12AB & 80G Applications Must Be Examined Independently; Earlier Rejection Does Not Bar Fresh Consideration – ITAT Bangalore Income Tax ITAT Dismisses Revenue Appeals on TP, Sales Tax Deferral & Section 14A Issues Income Tax ITAT Quashes Black Money Assessment Against Resident Not Ordinarily Resident for Lack of Jurisdiction Corporate Law Property Purchased Jointly With Spouse Not Benami Under 1988 Act: Kerala HC Custom Duty CESTAT Sets Aside Confiscation of Exotic Birds for Lack of Smuggling Proof Custom Duty CESTAT Quashes Confiscation of Gold for Curable Advance Authorisation Lapse Income Tax ITAT Mumbai Sets Aside Section 12AB Registration Rejection for Wrong Form 10AB Section Code Goods and Services Tax Gauhati HC Quashes GST Registration Cancellation Notice for Vagueness
Income Tax

Taxability of Architectural services provided by a limited partnership under the provisions of DTAA with USA

By TG Team Income Tax Judiciary April 3, 2010
Share:

Case Law Details

Case Name
Re. HMS Real Estate Pvt. Ltd. (A.A.R) No. 832 of 2009)
Courts
Advance Rulings
Upgrade to Basic or Premium to download.

Already Upgraded? Log in.

Advertisement
AAR Ruling: Architectural services provided by a limited partnership is liable to tax as “fees for technical / included services” as per the provisions of India- US Double Taxation Avoidance Agreement [HMS Real Estate Pvt. Ltd. (A.A.R. No. 832 of 2009)]. Facts: HMS Real Estate Pvt. Ltd. (applicant) is an Indian company engaged in the business of development and management of commercial real estate. The applicant proposed to construct an international quality commercial office/ hotel complex in Gurgaon. For this purpose, the applicant has entered into an agreement with Hellmuth, Obata + Kas...
This is premium content. Please become a Premium member. If you are already a member, login here to access the full content.
Advertisement
Filed under

Join TaxGuru's Network for the latest updates on Income Tax, GST, Company Law, Corporate Laws and other related subjects.

Related Articles in Income Tax
Fresh U/s 12AB & 80G Applications Must Be Examined Independently; Earlier Rejection Does Not Bar Fresh Consideration – ITAT Bangalore

Fresh U/s 12AB & 80G Applications Must Be Examined Independently; Earlier Rejection Does Not Bar Fresh Consideration – ITAT Bangalore

July 25, 2026
ITAT Dismisses Revenue Appeals on TP, Sales Tax Deferral & Section 14A Issues

ITAT Dismisses Revenue Appeals on TP, Sales Tax Deferral & Section 14A Issues

July 25, 2026
ITAT Quashes Black Money Assessment Against Resident Not Ordinarily Resident for Lack of Jurisdiction

ITAT Quashes Black Money Assessment Against Resident Not Ordinarily Resident for Lack of Jurisdiction

July 25, 2026
ITAT Mumbai Sets Aside Section 12AB Registration Rejection for Wrong Form 10AB Section Code

ITAT Mumbai Sets Aside Section 12AB Registration Rejection for Wrong Form 10AB Section Code

July 25, 2026
ITAT Allows TDS Credit Despite Wrong Deduction Under Assessee’s PAN

ITAT Allows TDS Credit Despite Wrong Deduction Under Assessee’s PAN

July 25, 2026
Gujarat HC Quashes Section 153C Assessment as Time-Barred Beyond Ten-Year Limitation

Gujarat HC Quashes Section 153C Assessment as Time-Barred Beyond Ten-Year Limitation

July 25, 2026
0 Comments

  1. We have similar kind of case but the recepient is a firm of companies. Would those are also covered by Article 15 of India – uS tax treaty.

    pls guide.

    thanks abhishek

    Reply
Leave a Reply

Your email address will not be published. Required fields are marked *