Allowing the appeal the Tribunal held that Indian branches of assessee, a French bank, paid data processing charges to its Singapore branch office, said payment could not be taxed as fees for technical services either under Income-tax Act and India-Singapore DTAA. AY. 2021-22)
BNP Paribas. v. ACIT (2024) 207 ITD 532 (Mum)(Trib.)
S. 9(1)(vii):Income deemed to accrue or arise in India-Fees for technical services-Data processing charges-Data processing charges paid to its Singapore branch office-Payment could not be taxed as fees for technical services either under Income-tax Act and India-Singapore DTAA-DTAA-India-Singapore.[S.90, Art. 12]
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