Income from Services provided by IMG to BCCI outside India not Taxable as FTS: Delhi HC

The Delhi High Court has ruled that income from services provided by the International Management Group (IMG) to the Board of Control for Cricket in India (BCCI) outside India is not taxable as Fees for Technical Services (FTS). The court emphasized that the services were utilized by BCCI outside India, and under the Double Taxation Avoidance Agreement (DTAA), such income is exempt from taxation in India. The bench clarified that the services rendered did not meet the criteria under Article 13 of the DTAA, which distinguishes between the utilization and transfer of technical or consulting services for business purposes.