Reimbursement on account of secondment of employees cannot be treated as FTS: ITAT Delhi

Ernst and Young U.S. LLP Vs ACIT (ITAT Delhi) ITAT Delhi held that cost to cost reimbursement on account of secondment of employees cannot be treated as Fees for Technical Services (FTS) as defined under Article 12 of India USA-DTAA. Thus, appeal of the assessee allowed. Facts- Ernst and Young U.S. LLP is a limited liability partnership. Further, the assessee is tax resident of United States of America (USA). The assessee is in the business of providing professional services in the field of assurance, tax, transaction and business advisory services etc. to its clients across the globe includin...