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2014 (2) TMI 902 - AAR - Income TaxNature of services provided - Existence of Permanent Establishment – DTAA between India and Brazil - Held that:- The services provided by the non-resident companies to the applicant company are line production services – it is been held in the applicant’s own case that the payments of similar nature are specifically characterized as work for the purpose of section 194C by Explanation to that section – thus, following the same ruling, the payments made by the applicant to the non-resident company specifically falls under the definition of work under section 194C of the IT Act and they will not be taxable without Permanent Establishment in India - the payment will not suffer withholding of tax under section 195 of the Income-tax Act, 1961.
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