Amount received towards IT and SAP charges not treatable as FTS hence not taxable

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 – Portugal DTAA...