https://www.taxtmi.com/caselaws?id=330114 A corporate guarantee commission earned for arranging a guarantee to a French bank was found to arise outside India, so it neither accrued nor was deemed to accrue in India under domestic law and was not taxable in India. The Tribunal also held that where the India-France DTAA caps royalty tax at 10% and defines income-tax to include surcharge, surcharge and education cess cannot be added separately to increase the treaty rate. The appeal therefore succeeded on both substantive tax issues; the interest grounds were treated as consequential. en-us Wed, 13 Jul 2016 00:00:00 +0530 Tue, 06 Feb 2018 16:03:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=330114 A corporate guarantee commission earned for arranging a guarantee to a French bank was found to arise outside India, so it neither accrued nor was deemed to accrue in India under domestic law and was not taxable in India. The Tribunal also held that where the India-France DTAA caps royalty tax at 10% and defines income-tax to include surcharge, surcharge and education cess cannot be added separately to increase the treaty rate. The appeal therefore succeeded on both substantive tax issues; the interest grounds were treated as consequential. Case-Laws Income Tax Wed, 13 Jul 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=330114