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Ancillary Software Services Protected Under DTAA as FTS Conditions Not Met
Case Law Details
- Case Name
- CA (Singapore) Pte. Ltd. Vs ACIT (ITAT Mumbai)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- 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 servi...
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