TMI BlogIncome deemed to accrue or arise in India - Collection of membership fees - We are in agreement with the...Income deemed to accrue or arise in India - Collection of membership fees - We are in agreement with the claim of the assessee that amount of profit that would be attributable to a PE would be on the basis of the extent appropriate to the role played by the PE in those transactions. In a case where the transactions had taken place outside India, the same cannot be attributed to the PE, because the PE had no role to play in such transactions. As such, only the portion of profits which are attribu..... ..... X X X X Extracts X X X X X X X X Extracts X X X X
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