Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
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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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