Protocol Forms Integral Part of DTAA: ITAT Delhi

DCIT Vs Converteam Group (ITAT Delhi) Income Tax Appellate Tribunal (ITAT) Delhi has dismissed an appeal filed by the Deputy Commissioner of Income Tax (DCIT) against Converteam Group, a French tax resident company, for Assessment Year 2015-16. The ruling affirms the Commissioner of Income Tax (Appeals) [CIT(A)]’s decision that management support services provided by Converteam Group to its Indian entities were not taxable as Fees for Technical Services (FTS) under the India-France Double Taxation Avoidance Agreement (DTAA). The core of the dispute revolved around the applicability of the &#...