Home Case Index All Cases Income Tax Income Tax + HC Income Tax - 2013 (10) TMI HC This
Forgot password New User/ Regiser ⇒ Register to get Live Demo
2013 (10) TMI 215 - HC - Income TaxTDS u/s 195 - whether reimbursement of lease line charges does/does not qualify as Royalty under Article 12 of India UK Treaty Amount attributable to PE in India or not Held that:- Amount received by the Respondent-Assessee as reimbursement of lease line charges and would not classify either as royalty or as income attributed to a Permanent Establishment in India - Reimbursement of lease line charges received by the Respondent-Assessee is the actual amount which is incurred by it on making payment to the international telecom operator - There is no income earned by Respondent-Assessee which is subject to tax but is only a reimbursement of lease line charges paid by it to international telecom operator Decided against the Revenue.
|