The Delhi Income Tax Appellate Tribunal (ITAT) issued an order on 7 September 2024 on whether a U.S. LLC is eligible for the benefits of the 1989 India-U.S. tax treaty. The case involved an LLC incorporated in the U.S. that received payments in the nature of fees for technical services/fees for included services from two Indian companies, which the U.S. LLC offered to tax at the rate of 15% as provided under the treaty. However, the assessing officer determined that the LLC, as a fiscally tr…