A
1 only
B
2 only
C
Both 1 and 2
D
Neither 1 nor 2
Correct answer: (b) 2 only
Explanation
Statement 1 is incorrect because the ITAT ruled that executive search fees do NOT constitute Fees for Technical Services (FTS) or royalties under bilateral tax treaties. Statement 2 is correct as under most DTAAs, FTS taxation requires the transfer of technical know-how under the make-available principle.
Same topic · past papers
UPSC has asked this before
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