Deduction u/s 80P(2)(a)(i) and 80P(2)(d) on bank interest remanded for AO's verification, including classification of compulsory investments and relat...
HC upheld the Tribunal's finding that the non-resident assessee did not have a service PE in India under Art. 5(6) of the India-Singapore DTAA for AYs 2020-21 and 2021-22. It approved exclusion of 36 vacation days from the employees' 120-day physical presence, resulting in only 84 days in India, below the 90-day threshold. HC held that only actual days of service rendering in India are relevant and rejected the Revenue's contention of a "virtual service PE," noting that such a concept is absent from both the DTAA and the domestic statute. Appeals were dismissed against the Revenue.
HC upheld the Tribunal's finding that the non-resident assessee did not have a service PE in India under Art. 5(6) of the India-Singapore DTAA for AYs 2020-21 and 2021-22. It approved exclusion of 36 vacation days from the employees' 120-day physical presence, resulting in only 84 days in India, below the 90-day threshold. HC held that only actual days of service rendering in India are relevant and rejected the Revenue's contention of a "virtual service PE," noting that such a concept is absent from both the DTAA and the domestic statute. Appeals were dismissed against the Revenue.
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