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Global Brand & Technology Support Payments Not Taxable as Royalty Under India-UK DTAA
Case Law Details
- Case Name
- DCIT Vs Deloitte Toutche Tohmatsu India LLP (ITAT Mumbai)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2018-19
- Courts
- All ITAT, ITAT Mumbai
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DCIT Vs Deloitte Toutche Tohmatsu India LLP (ITAT Mumbai)
No TDS Required on Internal Global Support Service Payments Due to Absence of Copyright Transfer; ITAT Deletes TDS Demand on Payments for Global Communication and Knowledge Management Services; Payments for Shared Global Services Not Royalty as No Intellectual Property Rights Were Transferred; Internal Network Software Usage Does Not Create Royalty Liability Under India-UK DTAA.
The appeals before the ITAT Mumbai concerned whether payments made by Deloitte Touche Tohmatsu India LLP to Deloitte Global Holdings Services L...
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