Service permanent establishment requires non-auxiliary services, while arm's-length distributor remuneration precludes further profit attribution in I...
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Income taxable in India or not - Taxation of Technical Collaboration Fees @ 10% u/s. 9(1)(vii) r.w.s 115A(1)(b) - The Appellate Tribunal considered the arguments presented by both parties and examined relevant provisions of the Income Tax Act and the India-Mauritius tax treaty. It noted that the assessee, being a foreign company, did not have a permanent establishment (PE) in India. Additionally, there was no specific clause in the tax treaty addressing the taxability of the income in question. - ITAT held that in the absence of a permanent establishment and specific treaty provisions, the income should be treated as business profits and is not taxable in India.
Income taxable in India or not - Taxation of Technical Collaboration Fees @ 10% u/s. 9(1)(vii) r.w.s 115A(1)(b) - The Appellate Tribunal considered the arguments presented by both parties and examined relevant provisions of the Income Tax Act and the India-Mauritius tax treaty. It noted that the assessee, being a foreign company, did not have a permanent establishment (PE) in India. Additionally, there was no specific clause in the tax treaty addressing the taxability of the income in question. - ITAT held that in the absence of a permanent establishment and specific treaty provisions, the income should be treated as business profits and is not taxable in India.
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