Non-Compete Premium is Business Income u/s 28(va) of Income Tax Act; Taxable Only in UK Per DTAA.

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....Non-compete premium received by assessee is a business receipt assessable u/s. 28(va) - as in term of Article- 7 of DTAA any business income arising to the enterprise of a contracting state is taxable only in that state, assessee being a non-resident company and does not have a permanent establishment in India, liable to tax in UK only - AT....