The Indian High Court issued its decision on 22 October 2012 in the case of DIT v. Siemens Aktiengesellschaft (ITA No. 124 of 2010) that the royalty / fees for technical services (FTS) would be taxable in the year in which the income is received. The High Court did not accept the contention of the tax authorities that the royalty or FTS should be taxed when the income is recorded in the books of accounts. The High Court while delivering its decision observed that article 12 of the Germany - India Income and Capital Tax Treaty uses the term "paid" in paragraph 1 and...