LLC as Fiscally Transparent Entity Under US Law eligible for India-USA DTAA Benefits

General Motors Company USA Vs ACIT (ITAT Delhi)

In this legal dispute, General Motors Company USA appealed against the orders passed by the Assessing Officer (AO)/ACIT, Circle Int. Tax 1(3)(1), New Delhi, relating to the assessment years 2014-15 and 2015-16. Since the grounds raised in both appeals were nearly identical, the ITAT Delhi heard them together and issued a combined order for convenience. The core issue revolved around the tax treatment of receipts classified as “Fees for Technical Services” (FTS) under the India-USA Double Taxation Avoidance Agreement (DTAA)

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