|Income Tax Appellate Tribunal
Market Data Charges & Employee Reimbursements Not Royalty or FIS/FTS Under India-US DTAA | ITAT Mumbai
The ITAT Mumbai has ruled that market data charges recovered from Indian associates and employee expense reimbursements received by a U.S.-based financial firm do not constitute royalty or fees for technical services under the India-US DTAA. This clarifies the tax treatment of cross-border cost recoveries for global financial institutions operating through non-PE structures in India, reinforcing the boundary between taxable service income and non-taxable reimbursement.