This is premium content. Please become a Premium member. If you are already a member, login here to access the full content.
Alibaba Subscription Fees Not FTS, Platform Is Mere Standard Facility: ITAT Mumbai
Case Law Details
- Case Name
- DCIT Vs Alibaba.com Singapore ECommerce Pvt. Ltd. (ITAT Mumbai)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2016-17
- Courts
- All ITAT, ITAT Mumbai
Upgrade to Basic or Premium to download.
Already Upgraded? Log in.
Advertisement
DCIT Vs Alibaba.com Singapore ECommerce Pvt. Ltd. (ITAT Mumbai)
Alibaba Subscription Fees Not FTS—Platform Is Mere Standard Facility; No Human Intervention, No “Make Available”
The Revenue filed three appeals against CIT(A)-5, Mumbai’s orders dated 13.02.2025 deleting additions made by AO by treating subscription receipts earned by Alibaba.com Singapore E-Commerce Pvt. Ltd. from Indian customers as Fee for Technical Services (FTS) under section 9(1)(vii) and Article 12 of India–Singapore DTAA.
1. Grounds 1 & 2—Infructuous (No Infomedia 18 issue in these years)
...






