Management Support Fees Not FTS Without ‘Make Available’ Under Article 12(4): ITAT Mumbai

Advertisement Tech Data (Singapore) Pte Limited Vs DCIT (ITAT Mumbai) The Mumbai ITAT partly allowed the assessee’s appeal against the assessment order passed under Section 143(3) read with Section 144C(13) of the Income Tax Act, 1961 for AY 2023-24. The assessee challenged the assessment on the grounds of limitation under Section 153 and the taxability of management support fees received from its Indian subsidiary. The Tribunal first rejected the limitation challenge, holding that in view of the retrospective amendments to Sections 144C, 153 and 153B, the assessment order had been passed...