Is Global Account Coordination Cost treated as Fees for Technical Services under the Income Tax Act?

Last updated: 15 July 2021
Quick Summary
This case concerns whether Global Account Coordination Cost should be classified as Fees for Technical Services under the Income Tax Act. The Assessing Officer made an addition of Rs. 57,38,948/- for non-deduction of tax on this cost. The assessee argued that tax should not have been deducted, citing provisions of the Act and the Double Taxation Avoidance Agreement (DTAA), and that retrospective amendments cannot impose tax withholding liability without services being rendered in India.

Court :
ITAT Delhi

Brief :
This appeal filed by the assessee for the assessment year 2008-09 is directed against the order of Ld. CIT(A)-20, New Delhi dated 31.03.2016. The assessee has raised following grounds of appeal:-

Citation :
ITA No.2252/Del/2016

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