Routine Group Support Not FTS or Royalty: ITAT Mumbai Grants ₹109.7 Cr Relief

Solvay S. A. Vs DCIT (ITAT Mumbai)

Routine Intra-Group Support Not FTS or Royalty – ITAT Mumbai Allows ₹109.7 Cr Relief

Key Issue

Whether ₹109.73 crore received by Solvay S.A., a Belgium-based multinational chemical company, from its Indian group entities for “functional support services” constituted Fees for Technical Services (FTS) or Royalty under s.9(1)(vii) & Article 12(3) of the India-Belgium DTAA.

Facts

Solvay S.A. rendered centralized & standardized services – such as IT infrastructure, procurement assistance

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