https://www.taxtmi.com/highlights?id=58208 Income deemed to accrue or arise in India - income attributable to India - As we have held that the ATC’s are not the DAPE of the assessee, therefore, the addition i.e 40% of the revenue generated from sale of distance learning material, attributed to them in their status as that of DAPE of the assessee corporation, viz. IATA, Canada, and assessed as the business income of the assessee in India under Article 7 of the India-Canada tax treaty cannot be sustained and is therefore vacated. - AT en-us Tue, 01 Jun 2021 16:53:37 +0530 Tue, 01 Jun 2021 16:53:37 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=58208 Income deemed to accrue or arise in India - income attributable to India - As we have held that the ATC’s are not the DAPE of the assessee, therefore, the addition i.e 40% of the revenue generated from sale of distance learning material, attributed to them in their status as that of DAPE of the assessee corporation, viz. IATA, Canada, and assessed as the business income of the assessee in India under Article 7 of the India-Canada tax treaty cannot be sustained and is therefore vacated. - AT Highlights Income Tax Tue, 01 Jun 2021 16:53:37 +0530 https://www.taxtmi.com/highlights?id=58208