Applicant filed an application seeking advance ruling on whether gross amounts paid/payable by applicant to a US Company under Distribution Agreement dated 1-10-2018 are in nature of Fees for Technical Services as per provisions of Explanation 2 to clause (vii) of section 9(1). Revenue submitted that it had no objection to admission of case Application for advance ruling was admitted.
Turnitindia Education (P) Ltd. In re (2021) 278 Taxman 389 (AAR)
S. 9(1)(vii) : Income deemed to accrue or arise in India-Fees for technical services-Gross amounts paid/payable by applicant to a US Company under Distribution Agreement was in nature of Fees for Technical Services-Application admitted-DTAA-India-USA. [S. 245R(2), Art. 12]