Intra-Group Services Not Taxable in India as They Fall Outside FTS Scope: ITAT Delhi

N.M. Rothschild & Sons Limited Vs DCIT (ITAT Delhi)

ITAT Delhi held that services rendered under Intra Group Service Agreement do not make available technical knowledge and hence would not fall within the definition of FTS as provided under Article 13(4) of India UK DTAA and hence not taxable in India.

Facts- Vide the present appeal, the assessee submits that the Assessing Officer erred in making an addition of Rs.2,47,83,056/- earned for services rendered under group service agreement and Rs.4,34,67,740/- towards fee for advisory services (aggregating t

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