https://www.taxtmi.com/caselaws?id=763317 Guarantee fee received by a Korean tax resident without a permanent establishment in India was held taxable only in Korea under Article 22 of the India-Korea DTAA. The Tribunal followed its earlier view in the assessee's own case and treated the receipt as income from other sources falling within the residuary treaty article, so India had no taxing right on these facts. Tax deduction at source and disclosure in the return did not change the treaty allocation, and the addition was deleted. en-us Wed, 30 Oct 2024 00:00:00 +0530 Tue, 17 Dec 2024 14:16:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=763317 Guarantee fee received by a Korean tax resident without a permanent establishment in India was held taxable only in Korea under Article 22 of the India-Korea DTAA. The Tribunal followed its earlier view in the assessee's own case and treated the receipt as income from other sources falling within the residuary treaty article, so India had no taxing right on these facts. Tax deduction at source and disclosure in the return did not change the treaty allocation, and the addition was deleted. Case-Laws Income Tax Wed, 30 Oct 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=763317