https://www.taxtmi.com/highlights?id=74476 Clubbing of income of Non-resident and Permanent Establishment (PE) - Levy of surcharge at 5% as against assessee’s claim of 2% - The royalty and Fee for Technical Services (FTS) income of the assessee, a non-resident corporate entity, should not be clubbed with the income of the Permanent Establishment for the purpose of surcharge under domestic law, as it is governed under the India-Germany Double Taxation Avoidance Agreement (DTAA). - The DTAA specifies a maximum tax rate of 10% on such income, and the imposition of a higher surcharge would violate this agreement. - AT en-us Tue, 30 Jan 2024 08:51:21 +0530 Tue, 30 Jan 2024 08:51:21 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=74476 Clubbing of income of Non-resident and Permanent Establishment (PE) - Levy of surcharge at 5% as against assessee’s claim of 2% - The royalty and Fee for Technical Services (FTS) income of the assessee, a non-resident corporate entity, should not be clubbed with the income of the Permanent Establishment for the purpose of surcharge under domestic law, as it is governed under the India-Germany Double Taxation Avoidance Agreement (DTAA). - The DTAA specifies a maximum tax rate of 10% on such income, and the imposition of a higher surcharge would violate this agreement. - AT Highlights Income Tax Tue, 30 Jan 2024 08:51:21 +0530 https://www.taxtmi.com/highlights?id=74476