ITA 1382/DEL/2022 – NM Rothchild & Sons Ltd: Taxability of Fees for Technical Services under India-UK DTAA

ITA 1382/DEL/2022 – NM Rothchild & Sons Ltd vs. DCIT: An Analysis of Fees for Technical Services under India-UK DTAA

This case involves NM Rothchild & Sons Ltd (the appellant) challenging the tax assessment by the Deputy Commissioner of Income Tax, International Taxation, Circle-2(2)(2), New Delhi (the respondent) for the assessment year 2019-20. The bone of contention revolves around the taxability of certain receipts earned by the assessee as Fees for Technical Services (FTS) under Article 13 of the India-United Kingdom (UK) Double Taxation Avoidance Agreement (DTAA).

Background of the Case

The case ITA No. 1382/DEL/2022 was filed alongside ITA No. 517/Del/2022 for the assessment year 2018-19, both concerning similar issues under scrutiny. The primary question was whether the amounts received by NM Rothchild & Sons Ltd for providing services to its associated enterprise, Rothschild & Co. India Pvt. Ltd., qualify as FTS under the India-UK DTAA.

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ITA 1382/DEL/2022 – NM Rothchild & Sons Ltd: Taxability of Fees for Technical Services under India-UK DTAA