‘Make Available’ Test Fails: IT Support Reimbursement Not FIS Under India’s DTAA

Invesco Holding Company (US) Inc. Vs ACIT (ITAT Delhi)

Routine IT Support Not Taxable as FIS Under India–US DTAA- No ‘Make Available’ of Technology – Cost-to-Cost Reimbursements Not Income in India -ITAT Delhi Deletes ₹54.85 Cr Addition; No Profit, No Tax: Cost-to-Cost Reimbursement for IT Services Excluded from Indian Income

ITAT Delhi deleted an addition of ₹54.85 crore made on reimbursements for IT support services received by Invesco Holding Company (US) Inc., holding that such payments were not taxable as Fees for In

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