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The HC upheld the ITAT's determination that receipts for freight/logistics support services constituted business income and did not qualify as fees for technical services or fees for included services under the Income-tax Act or under the India-USA DTAA; accordingly, the tax addition treating such receipts as FTS/FIS was deleted. The court further affirmed that the ITAT's prior rulings for the relevant assessment years were not to be disturbed, rejecting Revenue's appeals and leaving the ITAT orders intact. The litigation involved multiple consolidated appeals which the HC dismissed, thereby sustaining the assessee's relief against characterization of logistics receipts as taxable under FTS/FIS.
The HC upheld the ITAT's determination that receipts for freight/logistics support services constituted business income and did not qualify as fees for technical services or fees for included services under the Income-tax Act or under the India-USA DTAA; accordingly, the tax addition treating such receipts as FTS/FIS was deleted. The court further affirmed that the ITAT's prior rulings for the relevant assessment years were not to be disturbed, rejecting Revenue's appeals and leaving the ITAT orders intact. The litigation involved multiple consolidated appeals which the HC dismissed, thereby sustaining the assessee's relief against characterization of logistics receipts as taxable under FTS/FIS.
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