Equalisation levy on specified services limited by PE and threshold exceptions, with separate income-tax exemption interaction clarified. The Equalisation Levy charges non-residents on consideration for specified services received from Indian residents or from non-residents with an Indian permanent establishment, subject to exclusions where services are effectively connected with a PE, where the annual consideration falls below the statutory threshold, or where payments are not for business purposes; the levy is inapplicable to consideration received on or after 1 April 2025. Income chargeable to the levy is exempt from income-tax under specified transitional provisions, but amounts treated as royalty or fees for technical services remain taxable under income-tax law and applicable agreements.
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Provisions expressly mentioned in the judgment/order text.
Equalisation levy on specified services limited by PE and threshold exceptions, with separate income-tax exemption interaction clarified.
The Equalisation Levy charges non-residents on consideration for specified services received from Indian residents or from non-residents with an Indian permanent establishment, subject to exclusions where services are effectively connected with a PE, where the annual consideration falls below the statutory threshold, or where payments are not for business purposes; the levy is inapplicable to consideration received on or after 1 April 2025. Income chargeable to the levy is exempt from income-tax under specified transitional provisions, but amounts treated as royalty or fees for technical services remain taxable under income-tax law and applicable agreements.
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