Delhi ITAT Rules No Tax on Technical Services to AE Without PE in India

Denso (Thailand) Co. Ltd Vs ACIT (ITAT Delhi)

The recent case of Denso (Thailand) Co. Ltd vs ACIT before the Delhi ITAT delves into the taxation of technical services provided by Denso to its Indian group companies under the India-Thailand Double Taxation Avoidance Agreement (DTAA). The dispute revolves around whether these services qualify as Fees for Technical Services (FTS) and the implications in the absence of a Permanent Establishment (PE) in India.

Denso, a Thai company, asserted that the services provided were akin to business activities and not subject to FTS taxati

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