The Delhi Income Tax Appellate Tribunal (ITAT) issued an order on 26 May 2023 concerning the treatment of payments for services provided to a company in India as taxable fees for technical services (FTS) under the India-UK tax treaty. The case involved Infobip Limited (the assessee), a UK company that provided services to its associated enterprise, bSmart Tech Pvt. Ltd. (BTPL). The assessee rendered centralized services to BTPL that were in the nature of financial support services, technical support services, sales support services, and legal support services. No tax was paid on the payments for these services. In reviewing the...