Saturday International Tax Gyan!! (SITG – 236) #taxmadeeasy #taxinpic
Avtec Ltd. vs ACIT [2024] 168 taxmann.com 692 (Delhi – Trib.) [29.11.2024]
“Payments for warehousing services are logistical in nature and do not qualify as ‘Fees for Technical Services’ (FTS) under Section 9(1)(vii) of the Income Tax Act or DTAA, as they do not ‘make available’ technical knowledge or skill. Hence, they are not taxable as FTS.”