Assessee, a Singaporean entity, offered management services and received money from its Indian subsidiary. AO observed that the Assessee did not demonstrate the nature of the services or the mode or manner in which they were added. The AO taxed them as Financial Technical Services u/s. 9(1)(vii) of the Act. The ITAT observed that though the AO has alleged that the Assessee has failed to furnish necessary details/documents, however, he has not elaborated what were the information required from the Assessee. The ITAT held that the view taken by the AO and the Ld. DRP was contrary to the facts of the case and hence deleted the addition. (AY. 2019-20)
Tagit Pte Ltd. v. DCIT (2024) 159 taxmann.com 93/122 ITR 717 (Delhi) (Trib.)
S. 9(1)(vii): Income deemed to accrue or arise in India-Fees for technical services-AO taxed the services of the Assessee as FTS-Held, AO did not clarify what information was required from Assessee-Addition is deleted-DTAA-India-Singapore.[Art. 12(4)(b)]
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