Subscription Charge Reimbursements not Amounts to ‘FIS’ under India-US DTAA or S.9(1)(vii) of

The Income Tax Appellate Tribunal (ITAT) granted relief by ruling that subscription charge reimbursements do not amount to Fees for Included Services (FIS) under the India-US Double Taxation Avoidance Agreement (DTAA) or Section 91(vii) of the Income Tax Act. The tribunal determined that these reimbursements were not for services rendered and thus not taxable under these provisions. This decision offers clarity on the taxation of cross-border reimbursements.