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2015 (9) TMI 957 - AT - Income TaxTransfer pricing adjustment - computation of the Arm’s Length Price - Management Service Fees (‘MSF’) received whether taxable in India as ‘Fees for Technical Services’ (‘FTS’) within the meaning of Article 12 of the India-Sweden read with the protocol thereto ? Held that:- Since the nature of services provided by the assessee company to its affiliates during A.Y. 2007-08 and 2008-09 are similar, therefore, following the decision of the Tribunal in assessee’s own case in the immediately preceding assessment year and in absence of any contrary material brought to our notice we hold that the Management Service Fees received by the assessee is not taxable in India on the principle of most favoured nation clause the payment received by the assessee company from its Indian subsidiaries cannot be brought to tax. We hold and direct accordingly. - Decided in favour of assessee.
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