As the income on account of the upfront appraisal fees was ...
Upfront appraisal fees deemed business income; not taxable in India due to no permanent establishment under DTAA Article 7.
September 24, 2012
Case Laws Income Tax HC
As the income on account of the upfront appraisal fees was business income and as the respondents did not have a permanent establishment in India, the same could not be charged to tax in India under Article 7 of the DTAA - HC
View Source