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The ITAT dismissed the Revenue's appeal, holding that payments made by the assessee to Deloitte Global Services Pvt. Ltd. for Global brand, Global Communications, and Global technology/Knowledge Management services do not constitute royalty under Article 13(3) of the India-UK DTAA. Following precedent established in the assessee's own case for A.Y. 2018-19 and 2019-20, the Tribunal determined that these payments fall outside the scope and definition of 'royalty' under Article 13(1) of the DTAA. Consequently, the assessee was not required to deduct tax at source under section 195 while making these payments to DGSHL.
The ITAT dismissed the Revenue's appeal, holding that payments made by the assessee to Deloitte Global Services Pvt. Ltd. for Global brand, Global Communications, and Global technology/Knowledge Management services do not constitute royalty under Article 13(3) of the India-UK DTAA. Following precedent established in the assessee's own case for A.Y. 2018-19 and 2019-20, the Tribunal determined that these payments fall outside the scope and definition of 'royalty' under Article 13(1) of the DTAA. Consequently, the assessee was not required to deduct tax at source under section 195 while making these payments to DGSHL.
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