Reimbursements cannot be termed as Fees for Technical Services under India US DTAA

Advertisement American Express (India) Pvt. Ltd. Vs JCIT (ITAT Delhi) Conclusion: In present facts of the case, the Hon’ble Tribunal held that reimbursements cannot be termed as Fees for Technical Services under section 9(1)(vii) of the Act and Article 12 (4) of India US DTAA. Facts: In the said case, there were different appeals filed by both assessee and revenue. But the main issue was in ITA No.2714/Del/2018 [Assessment Year 2012-­13], wherein the facts were that Income Tax return declaring income of Rs.2,12,33,10,464/- was e-filed on 29.11.2012 which was subsequently revised and a re...