Home Case Index All Cases Income Tax Income Tax + AT Income Tax - 2022 (5) TMI AT This
Forgot password New User/ Regiser ⇒ Register to get Live Demo
2022 (5) TMI 161 - AT - Income TaxIncome accrued in India - Taxability of the receipts - gross basis or on net basis - Receipts in nature of ‘fee for technical services’ are to be taxed on net basis under section 44DA - Whether receipts were not ‘effectively connected’ with the PE of assessee in Indian and thus were liable to be taxed on gross basis @ 10% u/s 115A? - HELD THAT:- As decided in own case [2022 (2) TMI 697 - ITAT DELHI] assessee's receipts from the contracts in India are not effectively connected with PE in India. Accordingly,as directed the Assessing Officer to tax such receipts on net basis as per section 44DA of the Act. - Decided against Revenue.
|