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“fees for technical services”

International TaxSection 9(1)(vii)Section 9(1)(vii)1,408 judgments

The decision most relied on for fees for technical services is Engineering Analysis Centre of Excellence (P) Ltd. v. CIT (432 ITR 471), cited in 914 judgments on BharatTax.

Leading authorities on fees for technical services

Engineering Analysis Centre of Excellence (P) Ltd. v. CIT
432 ITR 471 · 2021 · Supreme Court
914
citing judgments

Payments for the supply or use of computer software, where there is no transfer of copyright but only a right to use the copyrighted product, are generally considered business profits and not 'royalty' or 'fees for technical services' under the Income Tax Act, 1961 or relevant DTAAs. This principle also applies to transponder fees, which are not taxable as royalty.

CIT v. De Beers India Minerals (P.) Ltd.
346 ITR 467 · 2012 · High Court
371
citing judgments

For fees for technical or consultancy services to 'make available' technical knowledge or know-how under a DTAA, the service must transmit such knowledge, allowing the recipient to derive an enduring benefit and utilize it independently in the future.

DIT v. Nokia Networks OY
358 ITR 259 · 2013 · High Court
276
citing judgments

Payments for the supply of software along with telecom equipment are not in the nature of royalty if they are for the use of a copyrighted article, not the copyright itself. Such payments are not taxable in India in the absence of a Permanent Establishment (PE).

DIT v. Infrasoft Ltd.
39 Taxmann.com 88 · 2013 · High Court
269
citing judgments

Payments for the use of copyrighted software, without the transfer of any rights in the underlying copyright itself, do not constitute 'royalty' under the Income-tax Act or tax treaties. Such payments are often treated as business income, taxable only if a permanent establishment exists.

CIT v. Siemens Aktiongesellschaft
310 ITR 320 · 2009 · High Court
259
citing judgments

Reimbursements of actual expenses without any profit element are not taxable income. Additionally, mere amendments to the Income-tax Act do not override the provisions of Double Taxation Avoidance Agreements (DTAAs).

Skycell Communications Ltd. v. DCIT
251 ITR 53 · 2001 · High Court
253
citing judgments

Technical services involve human intervention and expertise, not just routine or machine-based operations. Routine customer support and standard facility provision through technology do not constitute technical services under the Act.

Transmission Corporation of Andhra Pradesh v. CIT
239 ITR 587 · 1999 · Supreme Court
243
citing judgments

The Supreme Court lays down principles for deducting tax at source (TDS) under Section 195 on payments to non-residents, including aspects of income deemed taxable in India and the application of Double Taxation Avoidance Agreements (DTAAs) under Section 90.

ONGC v. CIT
376 ITR 306 · 2015 · Supreme Court
241
citing judgments

Income derived by a non-resident for services related to mineral oil operations, falling under the presumptive taxation regime of Section 44BB, cannot simultaneously be treated as fees for technical services under Section 9(1)(vii). The specific presumptive provisions override the general FTS definition, particularly when DTAA applies.

Judgments citing fees for technical services

Play Games 24 X 7 Private Limited, Mumbai vs. Dy.CIT-13(1)(2), Mumbai

In the result, the appeal filed by the assessee is allowed whereas the Cross-objection filed by the Revenue is dismissed

ITA 1533/MUM/2019[2015-16]Status: DisposedITAT Mumbai23 Mar 2022AY 2015-16

Bench: Shri Promod Kumar () & Ms. Suchitra Kamble () Assessment Year: 2015-16

For Appellant: Mr. Percy J. Pardiwala, Sr. AdvocateFor Respondent: Mr. Chintamani V. Dingankar, Sr. DR
Section 195Section 40Section 9Section 9(1)(vii)

payments made to Facebook, Ireland (‘Facebook’) towards banner advertisement expenses amounting to INR 10,46,35,355 are in the nature of Fees for Technical Services (‘FTS’) which are rendered in India and hence within the meaning of Section 9(1)(vii) of the Act and thereby, erred in disallowing ... decision erred in not holding the payment made by the assesse to Facebook as Royalty and instead held it as fee for technical services (FTS) and liable for TDS deduction u/s 40(a)(i) of the Act. 2. For these and other grounds that may be urged at the time

The Deputy Commissioner of Income Tax, Central Circle- 2(1), Mysuru vs. Shri. H Omkarappa (HUF), Shivamogga

In the result, the appeal of the Revenue is dismissed

ITA 2192/BANG/2019[2008-09]Status: DisposedITAT Bangalore18 Mar 2022AY 2008-09

Bench: Shri N.V. Vasudevan & Shri B. R. Baskaranassessment Year :2008-09 The Income Tax Officer, Vs. Shri. H. Omkarappa, (Huf), Ward - 1, #3, A Block, Apmc Yard, Shivamogga Sagar Road, Shivamogga. Pan : Aabhh 1124 B Appellant Respondent Assessee By : Shri. Shri. S. Ramasubramanyam, Ca Revenue By : Shri. Sankar Ganesh K, Jcit(Dr)(Itat), Bengaluru. Date Of Hearing : 10.03.2022 Date Of Pronouncement : 16.03.2022 O R D E R

For Appellant: Shri. Shri. S. Ramasubramanyam, CAFor Respondent: Shri. Sankar Ganesh K, JCIT(DR)(ITAT), Bengaluru
Section 133ASection 143(3)Section 40Section 68

April 1, 2010, and now reads as under : "40(a)(ia) any interest, commission or brokerage, rent, royalty, fees for professional services or fees for technical services payable to a res ident, or amounts payable to a contractor or sub-contractor, being resident, for Page 11 of 12 carrying

M/S Hindustan Aeronautics Limited, Bangalore vs. Assistant Commissioner of Income Tax Circle-3(1)(2), Bangalore

In the result, the appeal of the assessee is allowed

ITA 83/BANG/2018[2009-10]Status: DisposedITAT Bangalore10 Mar 2022AY 2009-10

Bench: Shri George George K & Ms. Padmavathy Sassessment Year : 2009-10

For Appellant: Shri Ajit Kumar Jain & Siddhesh Chaugule, ARsFor Respondent: Smt. S Praveena, CIT(DRP-2)
Section 143(3)Section 147Section 148Section 234BSection 250Section 40Section 40aSection 9(1)(vii)

assessees, which the assessee can apply independently and without assistance and undertake such survey independently. Consequently, the consideration is not assessable as “fees for technical services” In view of the above, we are of the considered opinion that fees paid by the assessee to CGTM France ... nature of fees for technical services and hence does not attract the provisions of sec. 195 with regard to requirement for deduction of tax at source on payment of fees for technical services of an resident outside India. As a result, no disallowance is warranted

M/S Playsimple Games Private Limited, Bangalore vs. Assistant Commissioner of Income Tax Circle - 5(1)(2), Bangalore

In the result, the appeal is allowed for statistical purposes

ITA 1125/BANG/2019[2016/17]Status: DisposedITAT Bangalore09 Mar 2022

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year: 2016-17

For Appellant: Shri Deepak Kumar Jain, CAFor Respondent: Shri Priyadarshi Mishra, Addl.CIT(DR)(ITAT), Bengaluru
Section 143(3)Section 195Section 234BSection 234DSection 40Section 9(1)(vi)

deduction of taxes at source. The Appellant, in their reply dated 22.10.2018 submitted that the impugned payments did not constitute royalty or fees for technical services. It further submitted that these parties Page 4 of 9 do not have a permanent establishment in India and hence these payments ... payable by the appellant. 7. Before the CIT(Appeals), the Appellant also submitted that the impugned payments do not constitute royalty or fees for technical services and supported the arguments on the basis of various judicial precedents in favour of the Appellant. It is submitted that

M/S. Asia Power Projects Private Limited, Bangalore vs. Deputy Commissioner of Income Tax, Bangalore

In the result appeals filed by assessee as well as revenue stands allowed for statistical purposes

ITA 59/BANG/2017[2011-12]Status: DisposedITAT Bangalore07 Mar 2022AY 2011-12

Bench: Shri. B.R. Baskaran & Smt. Beena Pillaiassessment Year : 2011-12 M/S. Asia Power Projects Pvt. The Deputy Ltd., Commissioner Of No. 6, Lakeside Residency, 4 Income Tax, Annaswamy Mudaliar Road, Circle – 11 (1), Bangalore – 560 042. Vs. Bangalore. Pan: Aadca0485B Appellant Respondent & Assessment Year : 2011-12 (By Revenue) : Shri Chavali Narayan, Ca & Assessee By Shri Keerthi Narayan, Ca : Shri Srinath Sadanala, Addl. Revenue By Cit (Dr) Date Of Hearing : 15-12-2021 Date Of Pronouncement : 07-03-2022 Order Per Beena Pillaipresent Cross Appeals Are Filed By Assessee As Well As Revenue Against The Order Dated 09.09.2016 Passed By The Ld.Cit(A)-1, Bangalore For Assessment Year 2011-12 On Following Grounds Of Appeal. “The Grounds Of Appeal Listed Below Are Without Prejudice To Each Other. 1. That The Order Of The Learned Deputy Commissioner Of Income-Tax (`A0') Dated 31 January 2014 & The Order

Section 115JSection 195Section 263Section 37Section 37(1)

DTAA respectively ie "Individual Personal Service"' (`IPS'). 3. The learned AO disallowed the payment made to non- resident freelancers considering the same as Fees for Technical Services (`FTS') and on account of non-deduction of TDS under section 195 of the Act. 4. The learned CIT(A) erred in confirming ... rendered by these people were some kind of technical expertise, skill or know how, and therefore it clearly covered by the definition of fee for technical services under the said tax treaties. The Ld.AO disallowed the payment of ₹ 20,56,737/- under section

Dy.Commissioner of Income Tax Circle-1(1)(1), Bangalore vs. M/S Asia Power Projects Private Limited, Bangalore

In the result appeals filed by assessee as well as revenue stands allowed for statistical purposes

ITA 211/BANG/2017[2011-12]Status: DisposedITAT Bangalore07 Mar 2022AY 2011-12

Bench: Shri. B.R. Baskaran & Smt. Beena Pillaiassessment Year : 2011-12 M/S. Asia Power Projects Pvt. The Deputy Ltd., Commissioner Of No. 6, Lakeside Residency, 4 Income Tax, Annaswamy Mudaliar Road, Circle – 11 (1), Bangalore – 560 042. Vs. Bangalore. Pan: Aadca0485B Appellant Respondent & Assessment Year : 2011-12 (By Revenue) : Shri Chavali Narayan, Ca & Assessee By Shri Keerthi Narayan, Ca : Shri Srinath Sadanala, Addl. Revenue By Cit (Dr) Date Of Hearing : 15-12-2021 Date Of Pronouncement : 07-03-2022 Order Per Beena Pillaipresent Cross Appeals Are Filed By Assessee As Well As Revenue Against The Order Dated 09.09.2016 Passed By The Ld.Cit(A)-1, Bangalore For Assessment Year 2011-12 On Following Grounds Of Appeal. “The Grounds Of Appeal Listed Below Are Without Prejudice To Each Other. 1. That The Order Of The Learned Deputy Commissioner Of Income-Tax (`A0') Dated 31 January 2014 & The Order

Section 115JSection 195Section 263Section 37Section 37(1)

DTAA respectively ie "Individual Personal Service"' (`IPS'). 3. The learned AO disallowed the payment made to non- resident freelancers considering the same as Fees for Technical Services (`FTS') and on account of non-deduction of TDS under section 195 of the Act. 4. The learned CIT(A) erred in confirming ... rendered by these people were some kind of technical expertise, skill or know how, and therefore it clearly covered by the definition of fee for technical services under the said tax treaties. The Ld.AO disallowed the payment of ₹ 20,56,737/- under section

Atos Information Technology Hk Ltd., Navi Mumbai vs. DCIT (It) - 1(1)(2), Mumbai

In the result, the appeal by the assessee stands partly allowed

ITA 7205/MUM/2018[2011-12]Status: DisposedITAT Mumbai01 Mar 2022AY 2011-12
Section 115ASection 143(3)Section 254Section 271(1)(c)Section 9Section 9(1)(i)Section 9(1)(vi)Section 9(1)(vii)

case and in law, the Learned AO and the DRP erred in holding the sum of Rs.40,46,45,646/- as 'Fees for Technical Services' under Section 9(1)(vii) of the Act. The Appellant humbly prays that the Learned AO be directed to not treat the aforesaid receipts ... Fees for Technical Services' u/s. 9(1)(vii) of the Act. 2 Atos Information Technology HK Limited 3. On the facts an in the circumstances of the case and in law, the Learned AO erred in considering business connection issue for the first time, which was not a subject matter

Asstt. CIT(It)-4(3)(1), Mumbai vs. M/S. Viacom 18 Media P. Ltd, Mumbai

In the result, the appeals filed by the revenue are dismissed

ITA 1138/MUM/2021[2019-20]Status: DisposedITAT Mumbai24 Feb 2022AY 2019-20

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm

For Appellant: Shri Nimesh Vora, ARFor Respondent: Shri Milind S. Chavan, SR DR
Section 195Section 9

contracting state in which they arise and according to the laws of that state, but if the beneficial owner of the royalties or fees for technical services is a resident of the other Contracting State, the tax so charged shall not exceed: (a) in the case of royalties within paragraph ... this Articles, and fees for technical services within paragraphs 4(a) and (c) of this Article,— (i) during the first five years for which this Convention has effect; (aa) 15 per cent of the gross amount of such royalties or fees for technical services when the payer of the royalties

Asstt. CIT(It)-4(3)(1), Mumbai vs. M/S. Viacom 18 Media P. Ltd, Mumbai

In the result, the appeals filed by the revenue are dismissed

ITA 1137/MUM/2021[2019-20]Status: DisposedITAT Mumbai24 Feb 2022AY 2019-20

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm

For Appellant: Shri Nimesh Vora, ARFor Respondent: Shri Milind S. Chavan, SR DR
Section 195Section 9

contracting state in which they arise and according to the laws of that state, but if the beneficial owner of the royalties or fees for technical services is a resident of the other Contracting State, the tax so charged shall not exceed: (a) in the case of royalties within paragraph ... this Articles, and fees for technical services within paragraphs 4(a) and (c) of this Article,— (i) during the first five years for which this Convention has effect; (aa) 15 per cent of the gross amount of such royalties or fees for technical services when the payer of the royalties

Asstt. CIT(It)-4(3)(1), Mumbai vs. M/S. Viacom 18 Media P. Ltd, Mumbai

In the result, the appeals filed by the revenue are dismissed

ITA 1136/MUM/2021[2019-20]Status: DisposedITAT Mumbai24 Feb 2022AY 2019-20

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm

For Appellant: Shri Nimesh Vora, ARFor Respondent: Shri Milind S. Chavan, SR DR
Section 195Section 9

contracting state in which they arise and according to the laws of that state, but if the beneficial owner of the royalties or fees for technical services is a resident of the other Contracting State, the tax so charged shall not exceed: (a) in the case of royalties within paragraph ... this Articles, and fees for technical services within paragraphs 4(a) and (c) of this Article,— (i) during the first five years for which this Convention has effect; (aa) 15 per cent of the gross amount of such royalties or fees for technical services when the payer of the royalties

Asstt. CIT(It)-4(3)(1), Mumbai vs. M/S. Viacom 18 Media P. Ltd, Mumbai

In the result, the appeals filed by the revenue are dismissed

ITA 1135/MUM/2021[2019-20]Status: DisposedITAT Mumbai24 Feb 2022AY 2019-20

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm

For Appellant: Shri Nimesh Vora, ARFor Respondent: Shri Milind S. Chavan, SR DR
Section 195Section 9

contracting state in which they arise and according to the laws of that state, but if the beneficial owner of the royalties or fees for technical services is a resident of the other Contracting State, the tax so charged shall not exceed: (a) in the case of royalties within paragraph ... this Articles, and fees for technical services within paragraphs 4(a) and (c) of this Article,— (i) during the first five years for which this Convention has effect; (aa) 15 per cent of the gross amount of such royalties or fees for technical services when the payer of the royalties

Asstt. CIT(It)-4(3)(1), Mumbai vs. M/S. Viacom 18 Media P. Ltd, Mumbai

In the result, the appeals filed by the revenue are dismissed

ITA 1134/MUM/2021[2019-20]Status: DisposedITAT Mumbai24 Feb 2022AY 2019-20

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm

For Appellant: Shri Nimesh Vora, ARFor Respondent: Shri Milind S. Chavan, SR DR
Section 195Section 9

contracting state in which they arise and according to the laws of that state, but if the beneficial owner of the royalties or fees for technical services is a resident of the other Contracting State, the tax so charged shall not exceed: (a) in the case of royalties within paragraph ... this Articles, and fees for technical services within paragraphs 4(a) and (c) of this Article,— (i) during the first five years for which this Convention has effect; (aa) 15 per cent of the gross amount of such royalties or fees for technical services when the payer of the royalties

Asstt. CIT(It)-4(3)(1), Mumbai vs. M/S. Viacom 18 Media P. Ltd, Mumbai

In the result, the appeals filed by the revenue are dismissed

ITA 1133/MUM/2021[2019-20]Status: DisposedITAT Mumbai24 Feb 2022AY 2019-20

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm

For Appellant: Shri Nimesh Vora, ARFor Respondent: Shri Milind S. Chavan, SR DR
Section 195Section 9

contracting state in which they arise and according to the laws of that state, but if the beneficial owner of the royalties or fees for technical services is a resident of the other Contracting State, the tax so charged shall not exceed: (a) in the case of royalties within paragraph ... this Articles, and fees for technical services within paragraphs 4(a) and (c) of this Article,— (i) during the first five years for which this Convention has effect; (aa) 15 per cent of the gross amount of such royalties or fees for technical services when the payer of the royalties

Asstt. CIT(It)-4(3)(1), Mumbai vs. M/S. Viacom 18 Media P. Ltd, Mumbai

In the result, the appeals filed by the revenue are dismissed

ITA 1132/MUM/2021[2019-20]Status: DisposedITAT Mumbai24 Feb 2022AY 2019-20

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm

For Appellant: Shri Nimesh Vora, ARFor Respondent: Shri Milind S. Chavan, SR DR
Section 195Section 9

contracting state in which they arise and according to the laws of that state, but if the beneficial owner of the royalties or fees for technical services is a resident of the other Contracting State, the tax so charged shall not exceed: (a) in the case of royalties within paragraph ... this Articles, and fees for technical services within paragraphs 4(a) and (c) of this Article,— (i) during the first five years for which this Convention has effect; (aa) 15 per cent of the gross amount of such royalties or fees for technical services when the payer of the royalties

Asstt. CIT(It)-4(3)(1), Mumbai vs. M/S. Viacom 18 Media P. Ltd, Mumbai

In the result, the appeals filed by the revenue are dismissed

ITA 1131/MUM/2021[2019-20]Status: DisposedITAT Mumbai24 Feb 2022AY 2019-20

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm

For Appellant: Shri Nimesh Vora, ARFor Respondent: Shri Milind S. Chavan, SR DR
Section 195Section 9

contracting state in which they arise and according to the laws of that state, but if the beneficial owner of the royalties or fees for technical services is a resident of the other Contracting State, the tax so charged shall not exceed: (a) in the case of royalties within paragraph ... this Articles, and fees for technical services within paragraphs 4(a) and (c) of this Article,— (i) during the first five years for which this Convention has effect; (aa) 15 per cent of the gross amount of such royalties or fees for technical services when the payer of the royalties

Asstt. CIT(It)-4(3)(1), Mumbai vs. M/S. Viacom 18 Media P. Ltd, Mumbai

In the result, the appeals filed by the revenue are dismissed

ITA 1130/MUM/2021[2019-20]Status: DisposedITAT Mumbai24 Feb 2022AY 2019-20

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm

For Appellant: Shri Nimesh Vora, ARFor Respondent: Shri Milind S. Chavan, SR DR
Section 195Section 9

contracting state in which they arise and according to the laws of that state, but if the beneficial owner of the royalties or fees for technical services is a resident of the other Contracting State, the tax so charged shall not exceed: (a) in the case of royalties within paragraph ... this Articles, and fees for technical services within paragraphs 4(a) and (c) of this Article,— (i) during the first five years for which this Convention has effect; (aa) 15 per cent of the gross amount of such royalties or fees for technical services when the payer of the royalties

Asstt. CIT(It)-4(3)(1), Mumbai vs. M/S. Viacom 18 Media P. Ltd, Mumbai

In the result, the appeals filed by the revenue are dismissed

ITA 1129/MUM/2021[2019-20]Status: DisposedITAT Mumbai24 Feb 2022AY 2019-20

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm

For Appellant: Shri Nimesh Vora, ARFor Respondent: Shri Milind S. Chavan, SR DR
Section 195Section 9

contracting state in which they arise and according to the laws of that state, but if the beneficial owner of the royalties or fees for technical services is a resident of the other Contracting State, the tax so charged shall not exceed: (a) in the case of royalties within paragraph ... this Articles, and fees for technical services within paragraphs 4(a) and (c) of this Article,— (i) during the first five years for which this Convention has effect; (aa) 15 per cent of the gross amount of such royalties or fees for technical services when the payer of the royalties

Asstt. CIT(It)-4(3)(1), Mumbai vs. M/S. Viacom 18 Media P. Ltd., Mumbai

In the result, the appeals filed by the revenue are dismissed

ITA 1097/MUM/2021[2019-20]Status: DisposedITAT Mumbai24 Feb 2022AY 2019-20

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm

For Appellant: Shri Nimesh Vora, ARFor Respondent: Shri Milind S. Chavan, SR DR
Section 195Section 9

contracting state in which they arise and according to the laws of that state, but if the beneficial owner of the royalties or fees for technical services is a resident of the other Contracting State, the tax so charged shall not exceed: (a) in the case of royalties within paragraph ... this Articles, and fees for technical services within paragraphs 4(a) and (c) of this Article,— (i) during the first five years for which this Convention has effect; (aa) 15 per cent of the gross amount of such royalties or fees for technical services when the payer of the royalties

Asstt. CIT(It)-4(3)(1), Mumbai vs. M/S. Viacom 18 Media P. Ltd., Mumbau

In the result, the appeals filed by the revenue are dismissed

ITA 1096/MUM/2021[2019-20]Status: DisposedITAT Mumbai24 Feb 2022AY 2019-20

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm

For Appellant: Shri Nimesh Vora, ARFor Respondent: Shri Milind S. Chavan, SR DR
Section 195Section 9

contracting state in which they arise and according to the laws of that state, but if the beneficial owner of the royalties or fees for technical services is a resident of the other Contracting State, the tax so charged shall not exceed: (a) in the case of royalties within paragraph ... this Articles, and fees for technical services within paragraphs 4(a) and (c) of this Article,— (i) during the first five years for which this Convention has effect; (aa) 15 per cent of the gross amount of such royalties or fees for technical services when the payer of the royalties

Asstt. CIT(It)-4(3)(1), Mumbai vs. M/S. Viacom 18 Media P. Ltd., Mumbai

In the result, the appeals filed by the revenue are dismissed

ITA 1095/MUM/2021[2019-20]Status: DisposedITAT Mumbai24 Feb 2022AY 2019-20

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm

For Appellant: Shri Nimesh Vora, ARFor Respondent: Shri Milind S. Chavan, SR DR
Section 195Section 9

contracting state in which they arise and according to the laws of that state, but if the beneficial owner of the royalties or fees for technical services is a resident of the other Contracting State, the tax so charged shall not exceed: (a) in the case of royalties within paragraph ... this Articles, and fees for technical services within paragraphs 4(a) and (c) of this Article,— (i) during the first five years for which this Convention has effect; (aa) 15 per cent of the gross amount of such royalties or fees for technical services when the payer of the royalties