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Ancillary Software Services Protected Under DTAA as FTS Conditions Not Met

CA Vijayakumar Shetty 17 Dec 2025 231 Views 1 comment Print
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Case Law Details

Case Name : CA (Singapore) Pte. Ltd. Vs ACIT (ITAT Mumbai)
Related Assessment Year : 2022-23
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CA (Singapore) Pte. Ltd. Vs ACIT (ITAT Mumbai)

Software Support ≠ FTS: ITAT Holds Ancillary Support Services to Be DTAA-Protected, Deletes ₹482.77 Cr FTS Addition

The Mumbai ITAT has partly allowed the appeal of CA (Singapore) Pte. Ltd. and deleted the addition of ₹48.27 crore made by treating ancillary support services linked

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Author Bio

CA Vijayakumar Shetty qualified in 1994 and in practice since then. Founding partner of Shetty & Co. He is a graduate from St Aloysius College, Mangalore . View Full Profile

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