Mere Passing of Architectural Drawings to AOP Not ‘FIS’, doesn’t satisfy ‘make believe’ under Article 12(4)(b) of India-USA DTAA: ITAT [Read Order]

The Delhi bench of the Income Tax Appellate Tribunal (ITAT) held that mere passing of project of specific architectural drawings and design with measurement did not amount to ‘make believe’ technical knowledge under 12(4)(b) of India-USA Double Taxation Avoidance Agreement (DTAA). The assessee, Michael Graves Design, is a privately held multifaceted and multi-discipline firm headquartered…