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]

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.