This article examines the tribunal’s decision in the case of Invesco UK Limited for the assessment year 2019-20. This case involved intricate issues related to the provision of support services to Invesco Group companies, highlighting significant considerations in international taxation and transfer pricing.
Invesco UK Limited, through its Hyderabad-based entity, provides extensive support services related to various applications and systems crucial for the Invesco Group’s operations. The assessment order and the subsequent appeal raise questions about the taxation of such international support services under Indian Tax Law.
The appeal follows a draft order issued by the Assessing Officer, which went through the processes outlined under Section 144C of the Income Tax Act, including interactions with the Dispute Resolution Panel (DRP). The final order was challenged on various grounds including procedural delays and statutory compliance, leading to this significant decision by the tribunal.
The tribunal’s decision touches upon critical aspects of the Income Tax Act, especially those related to the timely submission of draft orders and the role of the Dispute Resolution Panel. The article will dissect these legal points and their implications for tax assessments involving international entities operating in India.
The conclusion of this case has broader implications for foreign companies operating in India through subsidiaries or related entities, particularly in how they manage compliance with complex Indian tax regulations. The tribunal’s decision underscores the importance of adhering to procedural timelines and the potential challenges in dispute resolution under Indian tax law.
Invesco UK Limited vs. ACIT: International Taxation Dispute for AY 2019-20
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