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Taxability of Architectural services provided by a limited partnership under the provisions of DTAA with USA
Case Law Details
- Case Name
- Re. HMS Real Estate Pvt. Ltd. (A.A.R) No. 832 of 2009)
- Courts
- Advance Rulings
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AAR Ruling: Architectural services provided by a limited partnership is liable to tax as “fees for technical / included services” as per the provisions of India- US Double Taxation Avoidance Agreement [HMS Real Estate Pvt. Ltd. (A.A.R. No. 832 of 2009)].
Facts:
HMS Real Estate Pvt. Ltd. (applicant) is an Indian company engaged in the business of development and management of commercial real estate. The applicant proposed to construct an international quality commercial office/ hotel complex in Gurgaon. For this purpose, the applicant has entered into an agreement with Hellmuth, Obata + Kas...
We have similar kind of case but the recepient is a firm of companies. Would those are also covered by Article 15 of India – uS tax treaty.
pls guide.
thanks abhishek