https://www.taxtmi.com/caselaws?id=177758 A non-resident Portuguese consultant's legal consultancy fees were treated as not chargeable to tax in India under the applicable DTAA because there was no fixed base or permanent establishment in India and the consultant stayed only 22 days, below the treaty threshold. As the treaty was more beneficial than section 9(1)(vii), section 195 withholding was not attracted, and the consequential demands under sections 201(1) and 201(1A) could not be sustained. en-us Thu, 08 Aug 2013 00:00:00 +0530 Mon, 18 Jan 2016 13:17:32 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=177758 A non-resident Portuguese consultant's legal consultancy fees were treated as not chargeable to tax in India under the applicable DTAA because there was no fixed base or permanent establishment in India and the consultant stayed only 22 days, below the treaty threshold. As the treaty was more beneficial than section 9(1)(vii), section 195 withholding was not attracted, and the consequential demands under sections 201(1) and 201(1A) could not be sustained. Case-Laws Income Tax Thu, 08 Aug 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=177758