Indian Supreme Court to Hear EY's 368 Crore Rupee Tax Appeal
The Supreme Court of India has issued a notice to the Income Tax Department regarding an appeal filed by Ernst & Young U.S. LLP involving 368 crore rupees.
The Supreme Court of India has issued a notice to the Income Tax Department regarding the appeal filed by Ernst & Young U.S. LLP against the Commissioner of Income Tax, in case SLP(C) No. 36320/2026, as reported by Taxscan on October 27, 2026.
The appeal challenges the Delhi High Court ruling which held that salary reimbursements computed on a cost basis for seconded employees are taxable as fees for technical services under the India-US Tax Treaty.
The case involves a disputed amount of 368 crore rupees, and the court has set December 1, 2026, as the return date for the case.
The issuance of the notice means that the Supreme Court will consider the appeal, without having resolved the tax issue in dispute yet.
What do these terms mean?
Crore Rupees: An Indian unit of measurement equal to ten million rupees, used to express large monetary sums.
Fees for Technical Services: Payments made for technical or advisory services, which are subject to tax under specific tax treaties.
Employee Secondment: An arrangement where an employee temporarily works for another company while maintaining their contractual relationship with their original company.
Weekly Newsletter
Read between the lines before everyone else. Decode the most important economic, tech, and decision-maker movements in the region.. in 5 minutes every Saturday.
