Technical know-how not made available- Sub-Contracting Charges Not Taxable as FIS in India

Spi Global US Vs ACIT (ITAT Delhi)

Introduction: Explore the analysis of the SPI Global US vs ACIT case, a significant legal battle that challenged the taxability of sub-contracting charges under the India-USA Double Taxation Avoidance Agreement (DTAA). In this case, the court evaluated whether the services provided by SPI Global US constituted “fees for included services” (FIS) as per Article 12(4)(b) of the DTAA.

Analysis: The case revolves a

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