Routine Rework Not Technical Service: Tribunal Upholds FTS Deletion

DCIT Vs Roop Automotives Ltd. (ITAT Delhi)

Routine Segregation ≠ Technical Service — ITAT Delhi Upholds Deletion of ₹4.81 Cr FTS Disallowance

Revenue challenged deletion of disallowances aggregating to ₹4,81,03,713 (segregation charges) and ₹21,74,568 (PE-related TDS issue under India–Poland DTAA). After condoning a 50-day delay, ITAT examined the nature of “segregation/rework” carried out abroad.

CIT(A) had treated the payments as non-technical, hence not FTS u/s 9(1)(vii). Revenue argued that invoices contained terms like sorting, re

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