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2005 (11) TMI 239 - AT - Income Tax
DTAA - Liable to pay tax versus paying tax - Held that: - being ‘liable to tax’ in the Contracting State does not necessarily imply that the person should actually be liable to tax in that Contracting State by the virtue of an existing legal provision but would also cover the cases where that other Contracting State has the right to tax such persons - irrespective of whether or not such a right is exercised by the Contracting State. -