Consultancy Services Not Taxable as FIS under Article 12 of India-US DTAA: ITAT

The Income Tax Appellate Tribunal (ITAT) ruled that consultancy services do not qualify as Fees for Included Services (FIS) under Article 12 of the India-US Double Taxation Avoidance Agreement (DTAA). The decision clarifies that certain consultancy services are not taxable under FIS provisions, offering relief to taxpayers engaged in cross-border transactions. This interpretation aligns with international tax principles and the specific terms of the DTAA between India and the United States.