Home Case Index All Cases Income Tax Income Tax + AAR Income Tax - 2005 (7) TMI AAR This
Forgot password New User/ Regiser ⇒ Register to get Live Demo
2005 (7) TMI 31 - AAR - Income TaxRemuneration paid to non-resident for employment exercised in India - Dutch BV, through tPOs, providing consultancy services to various projects in India - POs derive income as fee for technical services from India – held that condition specified under sub-clause (c) of clause 2 of article 15 of DTAA relates to the taxability of employees and not of the applicant and is therefore, not relevant when Dutch BV is taxed in India, on presumptive basis under the provisions of s. 44D & s. 115A
|