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2015 (8) TMI 457 - AUTHORITY FOR ADVANCE RULINGS

2015 (8) TMI 457 - AUTHORITY FOR ADVANCE RULINGS - [2015] 373 ITR 658 (AAR) - Taxability of the income generated by fees for technical services (FTS) - applicant relies on DTAA between India and Belgium and also the DTAA between India and Portugal and, since the Portugal Treaty goes beyond the Treaty in between India and Belgium as per the protocol the applicant will be entitled to take the benefit of Portugal Treaty also - Held that:- We examined the application threadbare. The three questions .....

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applicant was convinced about the taxability of the royalty and interest income.

In our opinion, therefore, this cannot be seen as a device to avoid the tax. In that view we would prefer to admit the application. We make it clear that the Department will be free to take such action as is permissible by law in respect of income on royalty and interest income aspect. - A. A. R. No. 1447 of 2013. - Dated:- 27-4-2015 - V. S. SIRPURKAR J.AND A. K. TEWARY, J. Piyush Kaushik, Advocate, and .....

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Agreement (DTAA) between India and Belgium and also the DTAA between India and Portugal. According to the applicant, since the Portugal Treaty goes beyond the Treaty in between India and Belgium as per the protocol the applicant will be entitled to take the benefit of Portugal Treaty also. 2. The Revenue, however, seriously opposes the admission on the ground that this application amounts to a device to avoid the payment of tax. According to Shri Bali and Ms. Anusha Khurana, in fact, after filin .....

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