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ITAT Delhi: Project-Specific Services Not Subject to FIS under India-USA DTAA
Case Law Details
- Case Name
- Michael Graves Design Group Inc Vs DCIT (ITAT Delhi)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2014-15
- Courts
- All ITAT, ITAT Delhi
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Michael Graves Design Group Inc Vs DCIT (ITAT Delhi)
ITAT Delhi held that passing of project-specific architectural drawings and designs with measurements did not amount to making available technical knowledge, know-how, or processes. Since ‘make available’ clause is not satisfied, services rendered to the AOP does not fall within the purview of FIS under Article 12(4)(b) of the India-USA DTAA.
Facts- The assessee is a privately held multi-faceted and multi-discipline firm headquartered in Princeton, New Jersey, USA. The firm provides design services for its clients all ov...
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