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 limit

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