Question 1

What is the leading case on Section 9(1)(vi)(iii)?

Accepted Answer

FTS. (iii). ACIT v. PCI Ltd. (12 Taxmann.com 59) is the decision most relied on for Section 9(1)(vi)(iii), cited in 12 judgments on BharatTax. Payments made by an assessee to a non-resident for training its personnel or customers to explain product features and impart usage instructions do not constitute Fees for Technical Services (FTS).

Question 2

Which cases are most cited on Section 9(1)(vi)(iii)?

Accepted Answer

FTS. (iii). ACIT v. PCI Ltd. (12 Taxmann.com 59) — 12 citing judgments.

Question 3

How many judgments discuss Section 9(1)(vi)(iii)?

Accepted Answer

BharatTax indexes 3 ITAT, High Court and Supreme Court judgments that discuss Section 9(1)(vi)(iii) (Section 9(1)(vi)(iii)).

“Section 9(1)(vi)(iii)”

Leading authorities on Section 9(1)(vi)(iii)

Judgments citing Section 9(1)(vi)(iii)

M/S. Idea Cellular Limited, Indore vs. The DCIT (TDS), Indore

M/S. Idea Cellular Limited, Indore vs. The DCIT (TDS), Indore

M/S. Idea Cellular Limited, Indore vs. The DCIT (TDS), Indore