Alibaba Subscription Fees Not FTS, Platform Is Mere Standard Facility: ITAT Mumbai

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) The Department mi...