ITAT Mumbai Directs Readjudication on FTS Tax Deduction for AO’s Oversight

Spark44 Demand Creation Partners Private Limited Vs ACIT (ITAT Mumbai) Introduction: The case of Spark44 Demand Creation Partners Private Limited vs. ACIT (Income Tax Appellate Tribunal, Mumbai) revolves around the failure of the Assessing Officer (AO) to consider India UK Double Taxation Avoidance Agreement (DTAA) provisions for tax deduction on Fees for Technical Services (FTS). Analysis: In this case, the appellant, Spark44 Demand Creation Partners Private Limited, contested the imposition of Tax Deducted at Source (TDS) liability at 20% on inter-company management fees paid to a non-reside...