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Section 144C in The Income Tax Act, 1961 [Entire Act]
Damco International A/S, Mumbai vs Dcit (It) 2(1)(1), Mumbai on 20 July, 2020
7. We find that in the case of Damco International AS vs. DCIT in ITA No.933 &
6465/Mum/2017 for assessment years 2012- 13 and 2013- 14, decided on
20/07/2020 the Tribunal has held that business support charges paid by Damco
India are not taxable as FTS/Royalty under the Act or the relevant DTAA as the
same is purely in the nature of reimbursement of cost.