Absence of ‘make available’ clause, services rendered not FTS under India-Netherland DTAA: ITAT grants Relief to Shell Global Solutions Intl [Read Order]

Absence -clause-services rendered - FTS under India-Netherland DTAA-ITAT grants Relief - Shell Global Solutions Intl-TAXSCAN

The Ahmedabad Bench of Income Tax Appellate Tribunal (ITAT) held that the condition of “make available” has not been satisfied in the instant set of facts and hence, the services do not qualify as Fees for Technical Services(FTS). The assessee, M/s. Shell Global Solutions International B.V. is a company incorporated in Netherlands and is engaged…

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