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LLC as Fiscally Transparent Entity Under US Law eligible for India-USA DTAA Benefits
Case Law Details
- Case Name
- General Motors Company USA Vs ACIT (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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General Motors Company USA Vs ACIT (ITAT Delhi)
In this legal dispute, General Motors Company USA appealed against the orders passed by the Assessing Officer (AO)/ACIT, Circle Int. Tax 1(3)(1), New Delhi, relating to the assessment years 2014-15 and 2015-16. Since the grounds raised in both appeals were nearly identical, the ITAT Delhi heard them together and issued a combined order for convenience. The core issue revolved around the tax treatment of receipts classified as “Fees for Technical Services” (FTS) under the India-USA Double Taxation Avoidance Agreement (...
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