Post-search scrutiny assessment remains available where original assessment limitation is unexpired, permitting timely completion under regular assess...
Income deemed to accrue or arise in India - income attributable to India - As we have held that the ATC’s are not the DAPE of the assessee, therefore, the addition i.e 40% of the revenue generated from sale of distance learning material, attributed to them in their status as that of DAPE of the assessee corporation, viz. IATA, Canada, and assessed as the business income of the assessee in India under Article 7 of the India-Canada tax treaty cannot be sustained and is therefore vacated. - AT
Income deemed to accrue or arise in India - income attributable to India - As we have held that the ATC’s are not the DAPE of the assessee, therefore, the addition i.e 40% of the revenue generated from sale of distance learning material, attributed to them in their status as that of DAPE of the assessee corporation, viz. IATA, Canada, and assessed as the business income of the assessee in India under Article 7 of the India-Canada tax treaty cannot be sustained and is therefore vacated. - AT
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4784
Join Channel
TaxTMI 
