Amount received as subscription charge reimbursements not to be considered as ‘FIS’ under India-US DTAA or u/s 9(1)(vii)

Korn Ferry (US) Vs ACIT (ITAT Delhi)

Conclusion: Amount received as reimbursements for expenses related to software subscription services should not be taxed as technical services income under Article 12 of the of the India-USA Double Taxation Avoidance Agreement ( DTAA ) or Section 9(1)(vii).

Held: Assessee-company received Rs.55,29,572/- for reimbursement and general management charges. It had submitted before AO that reimbursement/general management charges had been received by it from Future step Recruitment Services Pvt. Ltd. and Hay Co

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