Payments for referral services cannot be termed as fees for technical services (FTS)

Facts

• The applicant, Real Resourcing Limited is a company incorporated in the UK and is a tax resident of the UK.
• The applicant provides recruitment services (the applicant places a candidate with an Indian company) and referral services (the applicant would refer potential Indian clients to a third party based in India).
• The applicant has an address in New Delhi –which is a virtual office wherein the applicant has rented use of the address and telephone numbers in New Delhi without a

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