The Mumbai Income Tax Appellate Tribunal recently issued its decision on whether commission fees paid in relation to a corporate guarantee deposited in a French bank are subject to tax. The case involved the French multinational management consulting company Capgemini, and its Indian subsidiaries Capgemini India Pvt. Ltd. and Capgemini Business Services (India) Ltd.
In the 2011-12 fiscal year, Capgemini deposited a corporate guarantee with BNP Paribas in France on behalf of its global subsid…