Cost reimbursement for support services taxable as Fees for Technical Services

Kraft Heinz Foods Company Vs DCIT (ITAT Mumbai) ITAT Mumbai held that cost reimbursement received towards providing support services is taxable as Fees for Technical Services (FTS) both under Section 9(1) (vii) of the Act as well as Article 12(4) of the Double Taxation Avoidance Agreement. Facts- The assessee is a resident of USA and is a leading manufacturer of food products and has a global presence. It has entered into a global agreement with effect from 3rd May, 2007, with its group entities for the provision of support activities. Heinz USA Pvt. Ltd. is one of the group entities in India....