https://www.taxtmi.com/caselaws?id=779846 The ITAT, Kolkata held that income from group services performed outside India does not arise in India and thus is not taxable in India under Article 12(5) of the India-Finland DTAA. Guarantee fees charged (0.1% of contract value) were held to be passive in nature, akin to bank guarantee fees, constituting income from other sources rather than business income and not attributable to a permanent establishment. Consequently the tribunal dismissed the assessee's ground and confirmed the assessing officer's order. en-us Mon, 25 Aug 2025 00:00:00 +0530 Tue, 14 Oct 2025 09:39:30 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=779846 The ITAT, Kolkata held that income from group services performed outside India does not arise in India and thus is not taxable in India under Article 12(5) of the India-Finland DTAA. Guarantee fees charged (0.1% of contract value) were held to be passive in nature, akin to bank guarantee fees, constituting income from other sources rather than business income and not attributable to a permanent establishment. Consequently the tribunal dismissed the assessee's ground and confirmed the assessing officer's order. Case-Laws Income Tax Mon, 25 Aug 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=779846