https://www.taxtmi.com/caselaws?id=772784 ITAT Delhi held that receipts from providing standard flight simulator services to Indian pilots in Ethiopia were not taxable as fee for technical services (FTS) in India. The tribunal rejected Revenue's arguments based on section 9(1)(vii) amendment and India-Ethiopia DTAA provisions, distinguishing standard simulator facilities from customized services. Following Delhi HC precedent in SFDC Ireland Ltd., the tribunal ruled that neither the assessee nor Dubai entity had taxable presence in India for these services. The assessee's appeal was allowed, with authorities erring in treating simulator receipts as FTS. en-us Thu, 05 Jun 2025 00:00:00 +0530 Tue, 10 Jun 2025 15:14:05 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=772784 ITAT Delhi held that receipts from providing standard flight simulator services to Indian pilots in Ethiopia were not taxable as fee for technical services (FTS) in India. The tribunal rejected Revenue's arguments based on section 9(1)(vii) amendment and India-Ethiopia DTAA provisions, distinguishing standard simulator facilities from customized services. Following Delhi HC precedent in SFDC Ireland Ltd., the tribunal ruled that neither the assessee nor Dubai entity had taxable presence in India for these services. The assessee's appeal was allowed, with authorities erring in treating simulator receipts as FTS. Case-Laws Income Tax Thu, 05 Jun 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=772784