ITAT Deletes FTS Addition Because India-UAE DTAA Contains No FTS Clause

Castlewick FZE Vs ACIT (ITAT Chennai) The appeal before the Income Tax Appellate Tribunal (ITAT), Chennai, concerned the assessment year 2018-19 and arose from a final assessment order passed under Sections 143(3) read with 144C(13) of the Income Tax Act, 1961. The assessee, a company incorporated in the UAE, challenged the taxability in India of an amount of ₹90 lakh received from an Indian entity, M/s. Gannon Dunkerley and Company Ltd. The payment was received for reviewing existing designs and drawings relating to a turnkey water supply distribution project at Jorhat, Assam. The assessee ...