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 Double Taxation Avoidance Agreement between India and The United States of America (DTAA). Appellant contented that receip...