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Income Tax - Highlights / Catch Notes

Home Highlights September 2012 Year 2012 This

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

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