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Payment by Indian Entity to AE Abroad Not ‘FTS’ if No Technical Skill Provided: Bangalore ITAT
Case Law Details
- Case Name
- Herbalife International India Pvt. Ltd. Vs DCIT (International Taxation) (ITAT Bangalore)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2013-14
- Courts
- All ITAT, ITAT Bangalore
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Herbalife International India Pvt. Ltd. Vs DCIT (International Taxation) (ITAT Bangalore)
In a landmark ruling, the Income Tax Appellate Tribunal (ITAT) of Bangalore addressed the issue of whether payments made by Herbalife International India Pvt. Ltd. to its associated enterprise (AE) abroad qualify as “Fees for Technical Services” (FTS) under Indian tax laws and the India-USA Double Taxation Avoidance Agreement (DTAA). This case, Herbalife International India Pvt. Ltd. Vs. DCIT (International Taxation), highlights the intricacies of international taxation, particularly in the co...
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