https://www.taxtmi.com/caselaws?id=763849 The ITAT Delhi ruled in favor of the appellant regarding Global Information Services (GIS) receipts from its Indian affiliate. The DRP and AO had classified routine GIS services including software/hardware maintenance and third-party services as Fees for Technical Services under Article 12 of the India-US DTAA. The ITAT found this classification lacked merit, noting the Indian affiliate had ceased motorcycle distribution operations during the relevant period, making claims of enduring benefit or technology transfer unfounded. The matter was remanded to the AO for fresh determination, with the appeal allowed for statistical purposes. en-us Fri, 27 Dec 2024 00:00:00 +0530 Mon, 30 Dec 2024 08:39:20 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=763849 The ITAT Delhi ruled in favor of the appellant regarding Global Information Services (GIS) receipts from its Indian affiliate. The DRP and AO had classified routine GIS services including software/hardware maintenance and third-party services as Fees for Technical Services under Article 12 of the India-US DTAA. The ITAT found this classification lacked merit, noting the Indian affiliate had ceased motorcycle distribution operations during the relevant period, making claims of enduring benefit or technology transfer unfounded. The matter was remanded to the AO for fresh determination, with the appeal allowed for statistical purposes. Case-Laws Income Tax Fri, 27 Dec 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=763849