https://www.taxtmi.com/highlights?id=83954 The Income Tax Appellate Tribunal (ITAT) held that the receipts received by the assessee, a foreign associated enterprise (AE), from HCLT for providing software, engineering, and infrastructure services were not taxable in India. The Assessing Officer (AO) had contended that the nature of these receipts should be considered "fees for technical services (FTS)" under Explanation 2 to Section 9(1)(vii) of the Income Tax Act and taxable under the Act and the India-Singapore DTAA. However, the ITAT agreed with the assessee's contention that HCLT was required to treat the entire sale proceeds received from foreign clients as export turnover under Explanation 2 to Section 10AA by raising a single consolidated invoice. The ITAT distinguished the fa..... en-us Fri, 13 Dec 2024 07:23:05 +0530 Fri, 13 Dec 2024 07:23:05 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=83954 The Income Tax Appellate Tribunal (ITAT) held that the receipts received by the assessee, a foreign associated enterprise (AE), from HCLT for providing software, engineering, and infrastructure services were not taxable in India. The Assessing Officer (AO) had contended that the nature of these receipts should be considered "fees for technical services (FTS)" under Explanation 2 to Section 9(1)(vii) of the Income Tax Act and taxable under the Act and the India-Singapore DTAA. However, the ITAT agreed with the assessee's contention that HCLT was required to treat the entire sale proceeds received from foreign clients as export turnover under Explanation 2 to Section 10AA by raising a single consolidated invoice. The ITAT distinguished the fa..... Highlights Income Tax Fri, 13 Dec 2024 07:23:05 +0530 https://www.taxtmi.com/highlights?id=83954