Cost-to-Cost Overseas Reimbursements Without Profit Element Not Taxable as FTS: ITAT Delhi

Horiba India Private Limited Vs Assessment Unit (ITAT Delhi) The Income Tax Appellate Tribunal (ITAT), Delhi, allowed the assessee’s appeal against the final assessment order for Assessment Year 2020-21, which had made corporate tax additions of ₹1,75,33,346 and a transfer pricing adjustment of ₹1,36,723. The dispute primarily related to reimbursements made to overseas group entities towards IT infrastructure and software costs, salary expenses, and travel expenses, which the Assessing Officer had treated as Fees for Technical Services (FTS) and disallowed for non-deduction of tax at...