https://www.taxtmi.com/caselaws?id=184742 Guarantee commission received by a French resident for corporate guarantees executed in France for Indian subsidiaries was treated as not taxable in India because the income neither accrued nor was deemed to accrue in India, and Article 23.3 of the India-France DTAA applied only to income arising in India. The corresponding addition was therefore unsustainable. The separate claim for tax deducted at source credit required verification by the Assessing Officer, who was directed to allow credit in accordance with law after checking the record. en-us Mon, 28 Mar 2016 00:00:00 +0530 Tue, 19 Jul 2016 11:27:32 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=184742 Guarantee commission received by a French resident for corporate guarantees executed in France for Indian subsidiaries was treated as not taxable in India because the income neither accrued nor was deemed to accrue in India, and Article 23.3 of the India-France DTAA applied only to income arising in India. The corresponding addition was therefore unsustainable. The separate claim for tax deducted at source credit required verification by the Assessing Officer, who was directed to allow credit in accordance with law after checking the record. Case-Laws Income Tax Mon, 28 Mar 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=184742