Application of the asseessee is admitted on the issue whether service charges received by assessee company towards provision of GDC HQ related services was liable to be taxed as fee for technical services under article 13 of India UK-DTAA.
Fujitsu Services Ltd. In re (2021) 279 Taxman 482 (AAR)
S. 245R : Advance rulings-Whether service charges received by assessee towards provision of GDC HQ related services was liable to be taxed as fee for technical services-Application admitted-DTAA-India-UK. [S. 9(1)(i), 245R(2), Art. 13]