ITAT Delhi Deletes Section 40(a)(ia) Disallowance as Travel Reimbursement Was Not FTS

DCIT Vs Fieldcore Service Solutions (ITAT Delhi) The Income Tax Appellate Tribunal (ITAT), Delhi, dismissed the Revenue’s appeal and upheld the order of the Commissioner of Income Tax (Appeals) [CIT(A)] deleting the disallowance of ₹91,69,670 made under Section 40(a)(ia) of the Income Tax Act. The disallowance had been made on the ground that reimbursement of travel and conveyance expenses paid to General Electric International Inc., USA, and Granite Services International Inc., USA, constituted Fees for Technical Services (FTS) under Section 9(1)(vii), requiring deduction of tax at source...