Advance-ruling mechanism governs pending GST classification, exemption and taxability disputes, limiting writ review once the specialised forum functi...
Charitable trust income application permits verified capital expenditure but rejects deferred pre-operative claims and requires reconsideration of con...
Reinsurance premium deductions require established regulatory breaches, while independently acquired software qualifies within the computer depreciati...
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4792
Join Channel
TaxTMI 
