Tax deduction compliance and payee income recognition govern consultancy disallowance, while no exempt income prevents related expenditure disallowanc...
Derivative abetment liability fails when correctly declared imported components establish no underlying improper importation by the principal importer...
The ITAT considered the issue of Fee for Technical Services (FTS) u/s 9(i)(vii) in a case involving reimbursement of connectivity charges. Assessing whether the services provided constituted technical, managerial, or consultancy services, it was found that the services were ancillary to enabling inter-connect services and product processing, not falling under the technical or managerial category. The Tribunal referred to a judgment in Bharti Airtel Ltd. case [2024 (1) TMI 804 - SC ORDER]. The assessee earned a 1% markup on reimbursement, with the AO advised to apply relevant Income Tax Act and DTAA provisions for taxation.
The ITAT considered the issue of Fee for Technical Services (FTS) u/s 9(i)(vii) in a case involving reimbursement of connectivity charges. Assessing whether the services provided constituted technical, managerial, or consultancy services, it was found that the services were ancillary to enabling inter-connect services and product processing, not falling under the technical or managerial category. The Tribunal referred to a judgment in Bharti Airtel Ltd. case [2024 (1) TMI 804 - SC ORDER]. The assessee earned a 1% markup on reimbursement, with the AO advised to apply relevant Income Tax Act and DTAA provisions for taxation.
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