Clean slate principle extinguishes uncrystallised operational claims and bars continuation of pending recovery and arbitral proceedings after plan app...
Works contract classification governs composite layout-development contracts where VAT-paid goods are transferred alongside construction and infrastru...
Specified income tax exemption for pollution control body remains conditional on non-commercial activity, unchanged income character, and return filin...
Jurisdictional facts in certificate-of-origin discrepancies can support customs show-cause proceedings, leaving factual explanations for departmental ...
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 4796
Join Channel
TaxTMI 
