The ITAT considered the issue of Fee for Technical Services ...

The tribunal ruled that the reimbursement of connectivity charges does not constitute technical, managerial, or consultancy services.

Case Laws Income Tax

June 21, 2024

The ITAT considered the issue of Fee for Technical Services (FTS) u/s 9(i)(vii) in a case involving reimbursement of connectivity charges. Assessing whether the services provided constituted technical, managerial, or consultancy services, it was found that the services were ancillary to enabling inter-connect services and product processing, not falling under the technical or managerial category. The Tribunal referred to a judgment in Bharti Airtel Ltd. case [2024 (1) TMI 804 - SC ORDER]. The assessee earned a 1% markup on reimbursement, with the AO advised to apply relevant Income Tax Act and DTAA provisions for taxation.

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The ITAT considered the issue of Fee for Technical Services ...

The tribunal ruled that the reimbursement of connectivity charges does not constitute technical, managerial, or consultancy services.

Case Laws Income Tax

June 21, 2024

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