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Income Tax - Highlights / Catch Notes

Home Highlights October 2023 Year 2023 This

Income accrued in India - engineering package fee and on-site ...

Income Tax

October 12, 2023

Income accrued in India - engineering package fee and on-site man-day charges - the service rendered by the assessee is in connection with installation/erection of plant and machinery involved in mining of natural resources - Scope of Article 5(2)(g) of India-Portugal DTAA is not merely limited to mining or extraction of natural resources but also covers installation or structure used for exploration and exploitation of nature resources. - The amount paid would not qualify as FTS. - Demand set aside - AT

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