Background screening receipts doesn’t qualify as Royalty/ FTS hence not taxable

HireRight Ltd Vs ACIT (ITAT Delhi) ITAT Delhi held that receipts from background screening provided by the assessee to its customers in India cannot be regarded as Royalty or Fees for Technical Services (FTS) under Article 13 of the India-UK DTAA and hence not taxable in India. Facts- The assessee is a foreign company and a tax resident of UK. The assessee does not have any permanent establishment in India. The assessee provided background screening and investigation services to its customers in India, however, the same was not offered to tax in India by the assessee. AO show caused the assess...