https://www.taxtmi.com/caselaws?id=6585 The Authority ruled that the condition specified under sub-clause (c) of clause 2 of Article 15 of the DTAA relates to the taxability of employees and not the applicant. Therefore, it is not relevant when Dutch BV is taxed in India on a presumptive basis under Section 44D and Section 115A of the Act. The ruling was pronounced on July 15, 2005. en-us Fri, 15 Jul 2005 00:00:00 +0530 Thu, 15 Jan 2009 00:00:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=6585 The Authority ruled that the condition specified under sub-clause (c) of clause 2 of Article 15 of the DTAA relates to the taxability of employees and not the applicant. Therefore, it is not relevant when Dutch BV is taxed in India on a presumptive basis under Section 44D and Section 115A of the Act. The ruling was pronounced on July 15, 2005. Case-Laws Income Tax Fri, 15 Jul 2005 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=6585