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    <title>Assessment orders confirm logistics/freight receipts are business income, not FTS/FIS under India-USA DTAA and Income-tax Act</title>
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    <description>The HC upheld the ITAT&#039;s determination that receipts for freight/logistics support services constituted business income and did not qualify as fees for technical services or fees for included services under the Income-tax Act or under the India-USA DTAA; accordingly, the tax addition treating such receipts as FTS/FIS was deleted. The court further affirmed that the ITAT&#039;s prior rulings for the relevant assessment years were not to be disturbed, rejecting Revenue&#039;s appeals and leaving the ITAT orders intact. The litigation involved multiple consolidated appeals which the HC dismissed, thereby sustaining the assessee&#039;s relief against characterization of logistics receipts as taxable under FTS/FIS.</description>
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    <pubDate>Fri, 10 Oct 2025 08:44:07 +0530</pubDate>
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      <title>Assessment orders confirm logistics/freight receipts are business income, not FTS/FIS under India-USA DTAA and Income-tax Act</title>
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      <description>The HC upheld the ITAT&#039;s determination that receipts for freight/logistics support services constituted business income and did not qualify as fees for technical services or fees for included services under the Income-tax Act or under the India-USA DTAA; accordingly, the tax addition treating such receipts as FTS/FIS was deleted. The court further affirmed that the ITAT&#039;s prior rulings for the relevant assessment years were not to be disturbed, rejecting Revenue&#039;s appeals and leaving the ITAT orders intact. The litigation involved multiple consolidated appeals which the HC dismissed, thereby sustaining the assessee&#039;s relief against characterization of logistics receipts as taxable under FTS/FIS.</description>
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      <pubDate>Fri, 10 Oct 2025 08:44:07 +0530</pubDate>
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