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Youcloud DMCC v. DCIT

Case No: ITA No.1220/Del/2024
Court: Income Tax Appellate Tribunal, Delhi Benches
Bench: Delhi Bench
Date: 2/6/2026

Parties Involved

appellantYoucloud DMCC
respondentDCIT

Facts Summary

The assessee, Youcloud DMCC, received Rs.1,02,54,839/- from M/s Comviva Technologies Ltd., India as Fee for Technical Services (FTS) during the financial year 2017-18, but did not offer it to tax in India. The Assessing Officer (AO) issued a re-assessment order adding this amount to the assessee's income. The assessee argued that the services were rendered outside India and hence not taxable in India. The AO rejected this contention, leading the assessee to file an appeal before the Tribunal.

Decision in favour of

Assessee

Legal Issues

  • 1. Whether the income received by the assessee as Fee for Technical Services is taxable in India.

Precedents Relied Upon

6 precedents cited in this judgement.

Judgment Outcome

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