Transfer-pricing aggregation of distinct support-service and subcontract transactions was rejected, while debt-free receivables attracted no notional ...
Customs exemptions cover photovoltaic assembly machinery and PVF backsheets, while fully declared cleared imports may avoid confiscation and penalties...
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ITAT resolved a tax dispute involving a UK-based engineering consultancy firm's income from services rendered in India. The Tribunal determined that payments received for consulting engineering services constitute business income under Article 7 of India-UK DTAA, not Fees for Technical Services (FTS). Since the company lacked a Permanent Establishment in India, the income was deemed non-taxable in India. The Tribunal upheld the assessee's position, consistent with its prior decisions in similar cases, and allowed the appeal, effectively exempting the income from Indian taxation.
ITAT resolved a tax dispute involving a UK-based engineering consultancy firm's income from services rendered in India. The Tribunal determined that payments received for consulting engineering services constitute business income under Article 7 of India-UK DTAA, not Fees for Technical Services (FTS). Since the company lacked a Permanent Establishment in India, the income was deemed non-taxable in India. The Tribunal upheld the assessee's position, consistent with its prior decisions in similar cases, and allowed the appeal, effectively exempting the income from Indian taxation.
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