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2016 (11) TMI 368 - AT - Income TaxTaxability in India - whether the Fees for Technical Services is chargeable to tax in India when Indo-UAE Double Taxation Avoidance Agreement (‘DTAA’) does not contain a clause/Article for taxation of Fees for Technical Services - P.E. in India - Held that:- In the absence of the provision in the DTAA to tax Fees for Technical Services the same would be taxed as per the Article 7 of the DTAA applicable for business profit and in the absence of PE in India, the said income is not chargeable to tax in India. Accordingly, we set aside the orders of the authorities below and delete the addition made by the Assessing Officer.- Decided in favour of assessee
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