Case Law Details
Case Name : CA (Singapore) Pte. Ltd. Vs ACIT (ITAT Mumbai)
Related Assessment Year : 2022-23
Courts :
All ITAT ITAT Mumbai
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CA (Singapore) Pte. Ltd. Vs ACIT (ITAT Mumbai)
Software Support ≠ FTS: ITAT Holds Ancillary Support Services to Be DTAA-Protected, Deletes ₹482.77 Cr FTS Addition
The Mumbai ITAT has partly allowed the appeal of CA (Singapore) Pte. Ltd. and deleted the addition of ₹48.27 crore made by treating ancillary support services linked to software distribution as Fees for Technical Services (FTS) under Article 12 of the India–Singapore DTAA for AY 2022-23.
The Assessee, a Singapore tax resident, distributed software licenses in India and provided support & maintenance services in relation t...
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