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Exclusion of Management Support Services from Article 12(4) of India-Singapore DTAA
Case Law Details
- Case Name
- Inter Continental Hotels Group [Asia Pacific] PTE Ltd Vs DCIT (ITAT Delhi)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2015-16
- Courts
- All ITAT, ITAT Delhi
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Inter Continental Hotels Group [Asia Pacific] PTE Ltd Vs DCIT (ITAT Delhi)
ITAT Delhi held that provision of management support services to various hotels in India doesn’t come under Article 12(4) of India -Singapore DTAA. Accordingly, addition unsustainable.
Facts- The assessee has preferred the present appeal contesting that the CIT(A) erred in treating the amount received by the assessee from Inter Continental Hotels Group [Asia Pacific] India Pvt Ltd [IHGAP] towards provision of Management Support Services to be in the nature of Fees for Technical Services [FTS] under Article 12 of the I...
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