https://www.taxtmi.com/caselaws?id=750905 ITAT Delhi held that receipts by foreign associated enterprises (AEs) from an Indian company under a Master Service Agreement were not taxable in India. The Tribunal found that the arrangement constituted revenue sharing rather than fee for technical services, as both Indian and foreign entities jointly served overseas customers with consolidated billing. The foreign AEs and Indian company worked together on client servers to develop final products, with the Indian company merely distributing customer payments proportionately. The Tribunal rejected the Assessing Officer's view that foreign AEs provided services to the Indian company, ruling the payments were not fee for technical services and decided in favor of the assessee. en-us Thu, 29 Feb 2024 00:00:00 +0530 Tue, 04 Mar 2025 11:57:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=750905 ITAT Delhi held that receipts by foreign associated enterprises (AEs) from an Indian company under a Master Service Agreement were not taxable in India. The Tribunal found that the arrangement constituted revenue sharing rather than fee for technical services, as both Indian and foreign entities jointly served overseas customers with consolidated billing. The foreign AEs and Indian company worked together on client servers to develop final products, with the Indian company merely distributing customer payments proportionately. The Tribunal rejected the Assessing Officer's view that foreign AEs provided services to the Indian company, ruling the payments were not fee for technical services and decided in favor of the assessee. Case-Laws Income Tax Thu, 29 Feb 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=750905