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2024 (5) TMI 687 - ITAT DELHI
Income taxable in India - payments received by the assessee from its India customers on account of Centralized Services - "Fee for Technical Services" as defined u/s 9(1)(vii) or “Fee for included services” as defined under Article 12(4)(a) of the Indo-US DTAA” - HELD THAT:- We find that this Tribunal in assessee’s own case [2023 (9) TMI 1470 - ITAT DELHI] for Assessment Year 2018-19 and for Assessment Year 2019-20 has decided the issue in favour as finding no reason to interfere with the decision of learned first appellate authority in declaring the receipts from centralized services to be not in the nature of FTS/FIS - Decided in favour of assessee.