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2013 (12) TMI 1169 - AAR - Income TaxAmount paid for production of television programme whether consitute fee for technical services - Held that:- As per Article 7 of the India-Singapore Tax Treaty - The profits of an enterprise of a Contacting State shall be taxable only in the State except if the profits of the enterprise are directly or indirectly attributable to the permanent establishment in the other state - The services of foreign company were utilized and payment for the services were also received outside India - There is no permanent establishment of that comany in India - Profits arising out of the transactions for services rendered by NAPL are not taxable in India - Decided in favour of assessee.
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