DTAA between India & USA – contract for repair and overhauling services of turbines – whether Fees for Technical Services

By TG Team Income Tax Judiciary June 3, 2012

Case Name: Re. Solar Turbines International Company (AAR Delhi)
Appeal Number: Only available for paid members
Date of Judgement/Order: Only available for paid members
Courts: Advance Rulings

Advertisement (1) Whether, based on the facts and circumstances of the case, receipts by the Applicant as per the Contract for the overhauling services would be taxable as Fees for Technical Services in India under the Act? – (2) Whether the consideration receivable under the Contract would fall within the definition of Fees for included services under Article 12 of the Indo-US DTAA? Would the services make available any technical knowledge, experience, skill, know-how, or processes, or consist of the development and transfer of a technical plan or technical design in terms of Indo-US...

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