International TaxArticle·10 July 2026
ITAT Clarifies Make available test for cross border services
By J the App
Executive Summary
The Bangalore Bench of the Income Tax Appellate Tribunal, in its order dated 29 June 2026, partly allowed the appeals of Sasken Technologies Ltd. across Assessment Years 2017-18 and 2020-21.
The Tribunal deleted the disallowance relating to payments made to overseas software service providers after holding that the "make available" condition under the India-US DTAA was not satisfied.
Domain | Direct Tax | International Tax
Background
The assessee, engaged in ...
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