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2017 (10) TMI 827 - AT - Income TaxIncome chargeable to tax in India - whether receipt by the assessee is not “ Royalty” under Article 12 of the Double Taxation Avoidance Agreement between India and Thailand - Held that:- Admittedly, the Hon'ble Delhi High Court in assessee's own case [2016 (2) TMI 415 - DELHI HIGH COURT] has considered the above issue in AY 2007-08 and AY 2009-10 on the identical facts and circumstances deciding that the amendment made by the Finance Act 2012 will not affect Article 12 of the DTAA and therefore, the income earned by the assessee cannot be held to be royalty and consequently to chargeable to tax in India.
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