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2013 (11) TMI 304 - AT - Income TaxRoyalties and fees for included services - whether the bio-equivalence study is a research activity - Non deduction of TDS - DTAA between India and Canada - Held that:- Applicant, tax resident of Canada, only providing final results to its Indian clients by using highly sophisticated bio-analytical know-how, without providing any access whatsoever to the clients to such know-how, fee received by it is business income and not fee for technical/included services or royalty and applicant having no PE in India, such income would not be taxable in India by virtue of relevant provisions of DTAA between India and Canada. - Decided against the revenue.
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