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The ITAT allowed the appellant's appeal regarding taxation of fees for technical services under the India-UAE DTAA. The appellant received amounts characterized as fees for technical services under Section 9(1)(vii) of the Income Tax Act. The tribunal determined that absent a permanent establishment in India and lacking specific DTAA provisions for taxing such fees, the income should be governed by Article 7 of the DTAA concerning business profits. Since the appellant had no PE in India, the fees were not chargeable to tax in India. The ITAT deleted the addition made by the assessing officer and ruled the amount non-taxable in India.
The ITAT allowed the appellant's appeal regarding taxation of fees for technical services under the India-UAE DTAA. The appellant received amounts characterized as fees for technical services under Section 9(1)(vii) of the Income Tax Act. The tribunal determined that absent a permanent establishment in India and lacking specific DTAA provisions for taxing such fees, the income should be governed by Article 7 of the DTAA concerning business profits. Since the appellant had no PE in India, the fees were not chargeable to tax in India. The ITAT deleted the addition made by the assessing officer and ruled the amount non-taxable in India.
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