Notification No. 12/97-Customs(N.T.) amendment adds Malur Inland Container Depot in Karnataka to authorized locations for import unloading and export ...
Authority rules B+G+31 service apartment is commercial building construction, not multi-storey residential for tax classification under RERA definitio...
ITAT affirmed deletion of an income addition and ruled in favour of the taxpayer, holding that reimbursements received from AEs for IT/support services constituted cost-to-cost allocations without profit and therefore did not constitute Fee for Included Services under the India-USA DTAA. The Tribunal found the "make-available" nexus absent because the services (desktop application training and routine IT administration) did not enable AEs to independently exploit any proprietary technology, and the AO failed to make requisite enquiries or rebut the taxpayer's factual record or the Master Inter-Company Services Agreement. Applying the coordinate bench precedent, the Tribunal concluded the AO's reliance on the taxpayer's own submissions was insufficient and deleted the addition.
ITAT affirmed deletion of an income addition and ruled in favour of the taxpayer, holding that reimbursements received from AEs for IT/support services constituted cost-to-cost allocations without profit and therefore did not constitute Fee for Included Services under the India-USA DTAA. The Tribunal found the "make-available" nexus absent because the services (desktop application training and routine IT administration) did not enable AEs to independently exploit any proprietary technology, and the AO failed to make requisite enquiries or rebut the taxpayer's factual record or the Master Inter-Company Services Agreement. Applying the coordinate bench precedent, the Tribunal concluded the AO's reliance on the taxpayer's own submissions was insufficient and deleted the addition.
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