Setting Sun on the Beneficial Tax Regime for Offshore Debt under the ECB and FPI-Rupee Bond Routes
by Manisha Shroff† Ritu Shaktawat††, and Sneh Shah†††
Cite as: 2023 SCC OnLine Blog Exp 64
External Commercial Borrowings
Payment received by assessee from foreign company for business support services cannot be treated as FTS under Art. 12 (5) of India Netherlands DTAA: ITAT reiterates
ITAT noted that an identical issue was subject matter of consideration of the Tribunal in assessee’s own case, hence following the precedent, the Tribunal directed that the payment received in this case cannot be treated as FTS under Article 12 (5) of India Netherlands DTAA.