Routine support services not taxable as Fees for Technical Services in terms of India-UK DTAA: ITAT Delhi

Nord Anglia Education Ltd Vs DCIT (ITAT Delhi)

ITAT Delhi held that routine support services would not be taxable as Fees for Technical Services (FTS) in terms of the provisions of India-UK Double Taxation Avoidance Agreement (DTAA).

Facts-

The Assessee is a company incorporated under the laws of United Kingdom (UK) and is a tax resident of UK in accordance with the Article 4 of the India-UK Double Taxation Avoidance Agreement. The Assessee has also entered into a service agreement with its group entity in India, i.e., PBIL for rendering certain centr

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