https://www.taxtmi.com/caselaws?id=204711 A foreign company treated as liable to tax in Germany, including trade tax, was regarded as a German resident for treaty purposes and could claim India-Germany DTAA benefits on royalty income under Article 12 at the reduced treaty rate, where it was the beneficial owner. The Tribunal also applied its earlier year's ruling that a non-resident whose income is subject to tax deduction at source is not liable to interest under sections 234B and 234C, following the same factual position. The first appellate authority's grant of treaty benefit and deletion of interest was therefore sustained. en-us Thu, 30 Sep 2010 00:00:00 +0530 Wed, 08 Aug 2012 14:51:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=204711 A foreign company treated as liable to tax in Germany, including trade tax, was regarded as a German resident for treaty purposes and could claim India-Germany DTAA benefits on royalty income under Article 12 at the reduced treaty rate, where it was the beneficial owner. The Tribunal also applied its earlier year's ruling that a non-resident whose income is subject to tax deduction at source is not liable to interest under sections 234B and 234C, following the same factual position. The first appellate authority's grant of treaty benefit and deletion of interest was therefore sustained. Case-Laws Income Tax Thu, 30 Sep 2010 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=204711