Consultancy service involving substantial technical skill cannot be treated as FIS

Bain & Company Vs Deputy/ACIT (ITAT Delhi)

ITAT Delhi held that as per India-USA DTAA provision of consultancy services cannot be treated as FIS merely because the service provider while providing consultancy services had used substantial technical skill and expertise.

Facts- The assessee is a non-resident corporate entity and a tax resident of the USA. As stated by AO, the assessee was engaged in the business of providing consultancy services to global clients based i

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