Receipt of fabrication charges from Associate Enterprise outside the purview of FTS

Owens Corning Inc. Vs DCIT (ITAT Mumbai) ITAT Mumbai held that fabrication charges received from Associate Enterprise doesn’t fall under the purview of fees for technical services (FTS) and accordingly not taxable in India. Facts- The assessee company is incorporated in Singapore and a group concern of Owens Corning Group of Companies, a leading manufacturer of glass. The assessee is engaged in the business of manufacturer and sale of glass fibers in India. AO found that there are receipts on account of fabrication charges of Rs. 15,75,67,856/- from its Indian Associate Enterprises namely OC...