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Ancillary Software Services Protected Under DTAA as FTS Conditions Not Met

Case Law Details

Case Name : CA (Singapore) Pte. Ltd. Vs ACIT (ITAT Mumbai)
Related Assessment Year : 2022-23
Courts : All ITAT ITAT Mumbai
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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 to software distribution as Fees for Technical Services (FTS) under Article 12 of the India–Singapore DTAA for AY 2022-23. The Assessee, a Singapore tax resident, distributed software licenses in India and provided support & maintenance services in relation t...
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Name: CA Vijayakumar Shetty
Qualification: CA in Practice
Company: Shetty & Co, Chartered Accountants, Mangalore
Location: Mangalore, Karnataka, India
Member Since: 17 Feb 2018 | Total Posts: 5366
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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