OrbitaxTreaty between India and Switzerland – Indian decision that e-commerce income from website operations in India is not fees for technical services and would not be taxable in absence of PE in India
|Treaty Development|India; Switzerland
The Income Tax Appellate Tribunal (ITAT) delivered its decision on 21 September 2012 in the case of eBay International AG v. ADIT (ITA No.6784/M/2010) that e-commerce income from the operation of an auction website is not characterized as fees for technical services (FTS) and accordingly, it is not subject to taxation under Indian Income Tax Act 1961 (ITA) in the absence of a perma…
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