Wednesday 5 March 2014

Foreign Co. while acting as lead manager and underwriting ADRs was not rendering any technical servi

IT/ILT : Where assessee, a UK based company, acted as lead manager and underwriter to ADRs/GDRs issued by Indian companies abroad for raising capital, it did not 'make available' technical services to Indian companies within meaning of article 13 of India-UK DTAA and, thus, payments made for rendering said services were not taxable in India as 'fee for technical services'


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