The Kolkata Income Tax Appellate Tribunal recently issued a decision on whether fees paid to overseas subsidiaries for marketing support services constitute fees for technical services (FTS). The case involved Batlivala & Karani Securities Pvt. Ltd. (B&K), an India-based brokerage company providing services for institutional clients.
In the year concerned, B&K paid service fees to its subsidiaries in Singapore and the UK for marketing support services for the expansion of its bus…