Branch Office as PE Allowed Full Cost Deduction Under DTAA

FCS Computer Systems S PTE Ltd. Vs ACIT (ITAT Delhi) Branch Office as PE Entitled to Full Cost Deduction — ITAT Allows ₹1.69 Crore Reimbursement under India–Singapore DTAA The Delhi Bench of the ITAT allowed the appeal of FCS Computer Systems (S) Pte Ltd., Singapore for AY 2022-23, deleting the disallowance of ₹1.69 crore relating to cost of goods sold and reimbursements charged by the Head Office to its Indian Branch (Permanent Establishment). The assessee’s Indian branch, treated as a PE under Article 5 of the India–Singapore DTAA, was engaged in sale of hospitality software and ...