In absence of cogent explanation ITAT treats consultancy charges as FTS & upheld addition

Kuiper Compagnons Rumtelikje Ordering Stedenbouw Architecture Landscape BV Vs DCIT (International Taxation) (ITAT Delhi) Undisputedly, in the year under consideration, the project office of the assessee had claimed deduction of consultancy charges paid to two overseas entities as expenses. However, in course of assessment proceedings, the assessee was unable to furnish any cogent explanation supported by evidence to establish that the consultancy charges paid are not in the nature of FTS. Further, on perusal of the directions of learned DRP, it is observed that similar disallowance under secti...