https://www.taxtmi.com/highlights?id=73782 Taxability of Income in India - The receipt of IUC charges cannot be taxed as Royalty under Article 13 in India of India-France DTAA. The payment received by the non-resident assessee amounts to be the business profits of the assessee which is taxable in the resident country and is not taxable in India under Article 5 of the DTAA as there is no case of permanent establishment of the assessee that has been made out by the revenue in India.- AT en-us Tue, 26 Dec 2023 16:07:26 +0530 Tue, 26 Dec 2023 16:07:26 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=73782 Taxability of Income in India - The receipt of IUC charges cannot be taxed as Royalty under Article 13 in India of India-France DTAA. The payment received by the non-resident assessee amounts to be the business profits of the assessee which is taxable in the resident country and is not taxable in India under Article 5 of the DTAA as there is no case of permanent establishment of the assessee that has been made out by the revenue in India.- AT Highlights Income Tax Tue, 26 Dec 2023 16:07:26 +0530 https://www.taxtmi.com/highlights?id=73782