https://www.taxtmi.com/highlights?id=5540 As the income on account of the upfront appraisal fees was business income and as the respondents did not have a permanent establishment in India, the same could not be charged to tax in India under Article 7 of the DTAA - HC en-us Mon, 24 Sep 2012 11:38:33 +0530 Mon, 24 Sep 2012 11:38:33 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=5540 As the income on account of the upfront appraisal fees was business income and as the respondents did not have a permanent establishment in India, the same could not be charged to tax in India under Article 7 of the DTAA - HC Highlights Income Tax Mon, 24 Sep 2012 11:38:33 +0530 https://www.taxtmi.com/highlights?id=5540