March 2019

Article 12 and Protocol to India-Belgium DTAA; Article 12, India-Portugal DTAA - due to MFN Clause in Protocol to India-Belgium DTAA, scope of FTS was to be restricted to that under India-Portugal DTAA and ‘make available’ condition was to be read into – as IT support services provided by a Belgian company did not ‘make available’ knowledge, experience, etc., the receipts were not in the nature of FTS.

Geeta Jani | Dhishat B. Mehta
Chartered Accountants

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