corporate and professional updates 23th july 2018
Direct Tax : Delhi ITAT upholds taxationย of consideration for providing SAP/CAD software related support as FTS under Article 13(4)(a), being ancillary and subsidiary to the enjoyment of the right / property for which royalty was received by assesseeย (a UK co., JCBE), clarifies that โmake availableโ clause under Article 13(4)(c) is not applicable; ITAT notes …