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Sum received for providing support services taxable as FTS if it satisfied make available clause: ITAT

August 28, 2019[2019] 108 473 (Delhi - Trib.)

INTERNATIONAL TAX: Where assessee a US based company had entered into a global agreement with its group entities (affiliates), including its Indian subsidiary for provision of support activities in area of supply chain, human resources, strategic planning and marketing, finance and information systems and from nature and duration of contract it was evident that services had been utilized by Indian Company as well and concept of make available which requires that fruits of services should remain available to service recipients in some concrete shape such as technical knowledge, experience, skills etc. was met, cost reimbursements received by assessee towards providing support services to its group affiliates would be taxable taxable as FTS both Income Tax Act and under tax treaty as well

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