“Payment to Self” Can’t Be Taxed as FTS: ITAT Deletes Addition on Reimbursement Paid by Indian PE to Australian Head Office

HomeDirect Tax“Payment to Self” Can’t Be Taxed as FTS: ITAT Deletes Addition on...

“Payment to Self” Can’t Be Taxed as FTS: ITAT Deletes Addition on Reimbursement Paid by Indian PE to Australian Head Office

Direct Tax

Published on

12/05/2026

By Mariya Paliwala

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The Delhi Bench of the Income Tax Appellate Tribunal (ITAT) has held that reimbursement of actual staff costs by an Indian Project Office (PO) to its Australian Head Office (HO) cannot be taxed as Fees for Technical Services (FTS), observing that a transaction with oneself cannot give rise to taxable income. The bench of Vikas…

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Mariya Paliwala https://www.jurishour.in/

Mariya is the Senior Editor at Juris Hour. She has 7+ years of experience on covering tax litigation stories from the Supreme Court, High Courts and various tribunals including CESTAT, ITAT, NCLAT, NCLT, etc. Mariya graduated from MLSU Law College, Udaipur (Raj.) with B.A.LL.B. and also holds an LL.M. She started her career as a freelance tax reporter in the leading online legal news companies.

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Payment to Self

“Payment to Self” Can’t Be Taxed as FTS: ITAT Deletes Addition on Reimbursement Paid by Indian PE to Australian Head Office

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