https://www.taxtmi.com/highlights?id=70207 Income deemed to accrue or arise in India - The centralised services income, by a reasonable measure, outstrips the royalty income. Thus, rather than centralised service income being ancillary and incidental to royalty income, in reality, it is a reverse situation. In such a scenario, it cannot be said that centralised service income, being ancillary and incidental to royalty income, would fall under Article 12(4)(a) of the Tax Treaty. - Additions deleted - AT en-us Thu, 08 Jun 2023 16:39:58 +0530 Thu, 08 Jun 2023 16:39:58 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=70207 Income deemed to accrue or arise in India - The centralised services income, by a reasonable measure, outstrips the royalty income. Thus, rather than centralised service income being ancillary and incidental to royalty income, in reality, it is a reverse situation. In such a scenario, it cannot be said that centralised service income, being ancillary and incidental to royalty income, would fall under Article 12(4)(a) of the Tax Treaty. - Additions deleted - AT Highlights Income Tax Thu, 08 Jun 2023 16:39:58 +0530 https://www.taxtmi.com/highlights?id=70207