Support/Maintenance Services of Avaya International Taxable as FTS under Article 12 of India – Ireland DTAA: ITAT Directs De Novo Adjudication [Read Order]

Support or Maintenance Services - Avaya International - Taxable - FTS - Article 12 of India – Ireland DTAA - DTAA - ITAT - De Novo Adjudication - ITAT Directs De Novo Adjudication - taxscan

The Delhi Bench of Income Tax Appellate Tribunal (ITAT) has directed a new adjudication holding that the support or maintenance services of Avaya international are taxable as Fees for Technical Services (FTS) under Article 12 of the India-Ireland Double Taxation Avoidance Agreement (DTAA). The appeal had been filed as to whether the payments received by…

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