https://www.taxtmi.com/caselaws?id=32098 AAR held that grant-funded fees payable to a non-resident contractor for a feasibility study were not taxable in India. The payment was made directly by a United States agency in the United States, the applicant only approved invoices, and the contractor had no office or establishment in India. On those facts, no income was received or deemed to be received in India, and no income accrued or arose in India under domestic law. The same result followed under the treaty because the effective payer and source of the payment were outside India. The ruling therefore negated Indian taxability of the receipt. en-us Fri, 13 Aug 2004 00:00:00 +0530 Thu, 15 Jan 2009 17:29:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=32098 AAR held that grant-funded fees payable to a non-resident contractor for a feasibility study were not taxable in India. The payment was made directly by a United States agency in the United States, the applicant only approved invoices, and the contractor had no office or establishment in India. On those facts, no income was received or deemed to be received in India, and no income accrued or arose in India under domestic law. The same result followed under the treaty because the effective payer and source of the payment were outside India. The ruling therefore negated Indian taxability of the receipt. Case-Laws Income Tax Fri, 13 Aug 2004 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=32098