Bombay High Court Allows Writ Petition Challenging Rejection of Nil Tax Withholding Certificate Under Section 197 of Income Tax Act, 1961 — Holds That Payments for International Delivery Services Are Not Royalty or Fees for Technical Services Under DTAA. The court directed issuance of nil withholding certificate as the payments are business profits not taxable in India under Article 7 of the India-USA DTAA.
30 Sep 2013The petitioner, UPS Worldwide Forwarding Inc., a US company, challenged an order dated 21 March 2013 passed by the Director of Income Tax (Internation...






