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Secondment Payments to EY US Taxable as FTS: Delhi HC
Case Law Details
- Case Name
- CIT Vs ERNST & Young U.S. LLP (Delhi High Court)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2018-19
- Courts
- All High Courts, Delhi High Court
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CIT Vs ERNST & Young U.S. LLP (Delhi High Court)
The Delhi High Court decided a batch of Revenue appeals under Section 260A of the Income-tax Act, 1961 relating to Assessment Years 2018-19 to 2022-23 involving Ernst & Young U.S. LLP. The appeals concerned (i) whether amounts received on account of secondment of employees to EY India entities constituted Fees for Technical Services (FTS) under Section 9(1)(vii) of the Income-tax Act and Article 12 of the India–USA DTAA, and (ii) whether receipts for services rendered in and from the USA qualified for exemption under Article 12(5)(e) r...
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