Tribunal held that the assessee had not provided complete details, accordingly in the interest of justice, whole issue set back to file of AO for deciding whether services involved in the agreement satisfy ‘ make Available’ criteria or not. (AY. 2010-11)
Ceva Asia Pacific Holdings Co. Pte Ltd. (2018) 192 TTJ 1 (UO) (Dehil)(Trib.)
S. 9(1)(vii) : Income deemed to accrue or arise in India-Fees for technical services-business of providing transportation, logistics, and supply chain solutions–Issue was sent back to for deciding whether services involved in the agreement satisfy ‘make Available’ criteria or not— DTAA-India–Singapore [Art. 12(4)]