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2020 (10) TMI 654 - AT - Income TaxIncome accrued in India - nature of fees for technical services - taxability of the amount received by the assessee from Expeditors International in respect of services performed outside India on the export consignments of Expeditors International originating from India - whether DRP is correct in holding that the receipts of the assessee do not fall within the scope of section 9(1)(i)? - HELD THAT:- On going through the provisions of the Act, facts of the case, business operations of the assessee, we hold that the services rendered by the assessee do not fall within the purview of managerial , consultancy or technical services. The payment for freight and logistics cannot be treated as technical services. Similarly, the provisions of Section 9(1)(i) are not attracted in this case as no income has accrued or arised from the business connection abroad in India. The explanation states that only that part of income from business operations can be said to be accruing or arising in India only if it is relatable to the carrying of operations in India. Thus, the payment received by the assessee neither falls under Section 9(1)(i) or Section 9(1)(vii). Hence, we hereby decline to interfere with the directions of the Dispute Resolution Panel in this case. - Decided against revenue.
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