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Reimbursements for seconded employees did not constitute FTS: Karnataka HC
Case Law Details
- Case Name
- Director of Income-Tax Vs Abbey Business Services India Pvt. Ltd. (Karnataka High Court)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2005-06
- Courts
- All High Courts, Karnataka High Court
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Director of Income-Tax Vs Abbey Business Services India Pvt. Ltd. (Karnataka High Court)
Karnataka High Court adjudicated the case of Director of Income-Tax vs. Abbey Business Services India Pvt. Ltd., concerning the applicability of tax deduction at source (TDS) on payments made to a non-resident under Section 195 of the Income Tax Act, 1961. The Revenue contended that payments made by Abbey India to Abbey UK for seconded employees constituted “fees for technical services” (FTS) under Section 9(1)(vii) and the India-UK Double Taxation Avoidance Agreement (DTAA). The Assessing Offi...
