Home Case Index All Cases Income Tax Income Tax + AT Income Tax - 2022 (11) TMI AT This
Forgot password New User/ Regiser ⇒ Register to get Live Demo
2022 (11) TMI 32 - AT - Income TaxRoyalty/FTS/FIS - Taxability of payment received by the assessee under Master Franchise Agreement as Royalty/Fee for Technical Services (FTS), both under the Domestic Law as well as India-USA Double Taxation Avoidance Agreement - (DTAA) - HELD THAT:- The factual position relating to the disputed issue being identical in the impugned assessment year, respectfully following the decision of the Tribunal in assessment year 2016-17 [2022 (7) TMI 781 - ITAT DELHI] we hold that the amount received by the assessee under the Master Franchise Agreement, cannot be treated either as a royalty/FTS/FIS. Accordingly, addition is deleted. Appeal is allowed.
|