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Income Tax - Highlights / Catch Notes

Home Highlights July 2019 Year 2019 This

Income accrued in India - PE - India-USA DTAA - taxability of ...


Income from 'Instructor Fee' at GIA India Lab not taxable in India under India-USA DTAA, no PE established.

July 18, 2019

Case Laws     Income Tax     AT

Income accrued in India - PE - India-USA DTAA - taxability of ‘Instructor Fee’ earned from ‘GIA India Lab’ - GIA India Lab is not acting in India on behalf of the assessee company nor having any authority to conclude contracts, it has neither concluded any contracts nor has it secured any orders for the assessee company in India, thus, cannot be regarded as agency PE - not taxable in India

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