https://www.taxtmi.com/caselaws?id=404226 ITAT Delhi held that receipts from international freight logistic support services were ordinary logistics activity, not managerial, consultancy, or technical services, so they did not fall within fees for technical services or fees for included services under section 9(1)(vii) or Article 12 of the India-USA DTAA; the addition was deleted. It further held that reimbursement of Global Account Management expenses, being an actual-cost allocation of group expenses incurred outside India without any separate income element, also lacked the character of technical services and failed the treaty "make available" requirement; that addition was likewise deleted. The assessee succeeded on both substantive grounds. en-us Thu, 11 Feb 2021 00:00:00 +0530 Fri, 19 Feb 2021 10:35:52 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=404226 ITAT Delhi held that receipts from international freight logistic support services were ordinary logistics activity, not managerial, consultancy, or technical services, so they did not fall within fees for technical services or fees for included services under section 9(1)(vii) or Article 12 of the India-USA DTAA; the addition was deleted. It further held that reimbursement of Global Account Management expenses, being an actual-cost allocation of group expenses incurred outside India without any separate income element, also lacked the character of technical services and failed the treaty "make available" requirement; that addition was likewise deleted. The assessee succeeded on both substantive grounds. Case-Laws Income Tax Thu, 11 Feb 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=404226