The ITAT determined that these amounts were reimbursed costs and did not constitute fees for technical services
The Delhi bench of Income Tax Appellate Tribunal ( ITAT ) granted relief ,ruling that the amount received as reimbursements for expenses related to software subscription services should not be taxed as technical services income under Article 12 of the of the India-USA Double Taxation Avoidance Agreement ( DTAA ) or Section 9(1)(vii) of the…
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