Edenred Pte Limited vs DCIT

Authority: ITAT Tribunal/Court: Mumbai Date: 2021-09-22 AY: 2016-17 Section: 184(5), 144, 44AD, 271(1)(c) Acts: Income Tax Act 1961, India-Singapore Double Taxation Avoidance Agreement (DTAA) Result: Assessee Citation: 921Taxpundit1503 Justices: SAKTIJIT DEY (JM) & RAJESH KUMAR (AM) Appeal No: I.T.A. No.6267/Mum/2019
Whether infrastructure data center charges, other service charges (referral fees), and member login fee received by a Singapore-based company from Indian group entities are taxable as royalty under the Income Tax Act 1961 and India-Singapore DTAA --- Held No.

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