Services doesn’t qualify as FTS as make available condition not satisfied: ITAT Ahmedabad

Shell International B.V. Vs ACIT (ITAT Ahmedabad)

ITAT Ahmedabad held that services do not qualify as Fee for Technical Services [FTS] under India-Netherlands tax treaty since department failed to demonstrate that technology was ‘make available’ to recipient of services.

Facts- The present appeal has been preferred by the assessee. The assessee submitted that the case of the assessee is covered by order passed in the case of this entity i.e. Shell International B.V. for A.Ys. 2009-10 to 2018-19 vide order dated 20.03.2024. The Counsel for the assessee su

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