No Disallowance Under Section 40(a)(i) if Technical Services Are Not Made Available to the Assessee
No Disallowance Under Section 40(a)(i) if Technical Services Are Not Made Available to the Assessee Issues Whether payments to US non-resident contractors for software services are taxable as “Fees for Included Services” under the India-USA DTAA if the “make available” condition is not satisfied. Whether payments to a UK entity for a website access license… Read More »