Cross-Cost Charges Not Royalty, AO to withholding Issue NIL Tax Certificate: Delhi HC

Aecom Technical Services Inc. Vs ITO (Delhi High Court) Delhi High Court held that payment of cross-cost charges doesn’t construed as royalties within scope of Article 12(3) of the India-US DTAA hence order rejecting application for NIL withholding tax set aside. AO directed to issue necessary certificate. Facts- The petitioner has filed the present petition, inter alia, impugning an order dated 26.07.2024 [impugned order] passed by the Assessing Officer [AO] under Section 197 of the Income Tax Act, 1961 [Act], whereby the petitioner’s application for ‘NIL’ withholding tax, was rejecte...