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Cross-Cost Charges Not Royalty, AO to withholding Issue NIL Tax Certificate: Delhi HC
Case Law Details
- Case Name
- Aecom Technical Services Inc. Vs ITO (Delhi High Court)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Courts
- All High Courts, Delhi High Court
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Aecom Technical Services Inc. Vs ITO (Delhi High Court)
Delhi High Court held that payment of cross-cost charges doesn’t construed as royalties within scope of Article 12(3) of the India-US DTAA hence order rejecting application for NIL withholding tax set aside. AO directed to issue necessary certificate.
Facts- The petitioner has filed the present petition, inter alia, impugning an order dated 26.07.2024 [impugned order] passed by the Assessing Officer [AO] under Section 197 of the Income Tax Act, 1961 [Act], whereby the petitioner’s application for ‘NIL’ withholding...






