Receipts taxable under FTS/FIS on failure to prove basis of cost allocation

Kraft Foods Group Brands LLC Vs ACIT (ITAT Mumbai)

ITAT Mumbai held that receipts taxable under Fees for Technical/ Included Services (FTS/FIS) as assessee failed to prove that it is actual reimbursement as there is no basis of allocation or actual cost incurred for affiliates.

Facts- Vide the present appeal, the appellant has mainly contested against taxability of receipts of INR 7,18,00,340/- as Fees for Technical/ Included Services (FTS/FIS) under the Income Tax Act and

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