https://www.taxtmi.com/caselaws?id=420608 The Tribunal ruled that the performance guarantee commission was not classified as business income under Article 7 of the DTAA. The income was deemed taxable in both India and Singapore under the residual head (Article 23). The assessee was granted foreign tax credit for the tax withheld in Singapore, in accordance with Section 90(1) and Rule 128 of the Income Tax Act, 1961. Consequently, the appeals for both assessment years were allowed, and the Assessing Officer was instructed to provide the tax credit. en-us Tue, 08 Mar 2022 00:00:00 +0530 Wed, 06 Apr 2022 10:45:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=420608 The Tribunal ruled that the performance guarantee commission was not classified as business income under Article 7 of the DTAA. The income was deemed taxable in both India and Singapore under the residual head (Article 23). The assessee was granted foreign tax credit for the tax withheld in Singapore, in accordance with Section 90(1) and Rule 128 of the Income Tax Act, 1961. Consequently, the appeals for both assessment years were allowed, and the Assessing Officer was instructed to provide the tax credit. Case-Laws Income Tax Tue, 08 Mar 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=420608