Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
Specialized Investment Fund distribution now requires dedicated certification, while transitional recognition preserves existing qualified distributor...
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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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