COURT: | ITAT Hyderabad |
CORAM: | P.M.Jagtap (AM), Saktijit Dey (JM) |
SECTION(S): | 9(1)(vii), Article 12 |
GENRE: | International Tax |
CATCH WORDS: | feed for included services, Fees for technical services, reimbursement of actual cost |
COUNSEL: | S. Raghunathan S. |
DATE: | October 22, 2014 (Date of pronouncement) |
DATE: | October 26, 2014 (Date of publication) |
AY: | 2007-08 |
FILE: | Click here to view full post with file download link |
CITATION: | |
In view of the finding of the service-tax authorities that services were rendered, argument that amount paid is a reimbursement of actual cost without profit element is not acceptable and it is chargeable as “fee for included services” |
Having held that the amount in question was remitted by the assessee company to ATI Technologies, Canada for certain benefits received by it in the form of services procured by ATI Technologies, Canada from Soctronics India Private Limited and provided …
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