Foreign portfolio investment liberalisation extends listed equity access to all individual persons resident outside India, subject to limit monitoring...
Levy of Surcharge and cess - to be computed over the rate of tax as per DTAA or not - Article 12 read with Article 2 of the tax treaty makes it clear that the rate of tax at 10% would encompass surcharge and education cess as it is also in the nature of surcharge. Therefore, we hold that levy of surcharge and cess over and above the taxable rate of 10% on royalty and FTS is not permissible as per the treaty provisions. - AT
Levy of Surcharge and cess - to be computed over the rate of tax as per DTAA or not - Article 12 read with Article 2 of the tax treaty makes it clear that the rate of tax at 10% would encompass surcharge and education cess as it is also in the nature of surcharge. Therefore, we hold that levy of surcharge and cess over and above the taxable rate of 10% on royalty and FTS is not permissible as per the treaty provisions. - AT
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