This is premium content. Please become a Premium member. If you are already a member, login here to access the full content.
Amount received towards IT and SAP charges not treatable as FTS hence not taxable
Case Law Details
- Case Name
- Netafim Ltd Vs DCIT (ITAT Delhi)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2014-15
- Courts
- All ITAT, ITAT Delhi
Upgrade to Basic or Premium to download.
Already Upgraded? Log in.
Advertisement
Netafim Ltd Vs DCIT (ITAT Delhi)
ITAT Delhi held that amount received from its Indian subsidiary towards IT and SAP charges cannot be treated as Fees for Technical Services (FTS) under Article 12(4)(a) of India – Portugal DTAA. Accordingly, additions unsustainable.
Facts- The only common issue arising for consideration in the present appeals is, whether the amounts received by the assessee from its Indian subsidiary towards IT and SAP charges can be treated as Fees for Technical Services (FTS) under India – Israel Double Taxation Avoidance Agreement (DTAA) read with India ...
Author Info
Thanks for sharing.