2 July 2010,Friday Kapil Goel B.Com(H) FCA LLB Advocate Delhi ...
2 July 2010,Friday Kapil Goel B.Com(H) FCA LLB Advocate Delhi ...
2 July 2010,Friday Kapil Goel B.Com(H) FCA LLB Advocate Delhi ...
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Bang ITAT – SunMicrosystems• India Singapore DTAA – Article 7 & Article 12 – FTS –• Logistic Services do no make available any technology• There is no evidence on record to show that serviceprovider company made available any technology• Revenue has not examined any employee of servicerecipient Indian Co to show that it could have utilized theexperience gained by itself…• Rulings referred: BHC in Diamond Services 216 CTR120; AAR in Intertek 307 ITR 418, Raymond 86 ITD 791