Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
ITAT held that passenger system services provided by a US-based company to an Indian airline do not constitute Fees for Technical Services (FTS) under Article 12 of India-USA DTAA. The tribunal determined that no specific technology was made available to the Indian entity, and the services were rendered using standard software supported by the service provider's data center. Consequently, the tribunal upheld the CIT(A)'s order, finding the receipts non-taxable in India, effectively dismissing the revenue department's contentions regarding taxation under section 9(1)(vii) of the Income Tax Act as procedurally academic.
ITAT held that passenger system services provided by a US-based company to an Indian airline do not constitute Fees for Technical Services (FTS) under Article 12 of India-USA DTAA. The tribunal determined that no specific technology was made available to the Indian entity, and the services were rendered using standard software supported by the service provider's data center. Consequently, the tribunal upheld the CIT(A)'s order, finding the receipts non-taxable in India, effectively dismissing the revenue department's contentions regarding taxation under section 9(1)(vii) of the Income Tax Act as procedurally academic.
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