Payment for Technical Services Classified as Business Profits Under DTAA Article 7; Not Taxable in India Without PE.

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....Receipt of Fees for Technical Services (FTS) - there is no dispute that the payment made was in the nature of FTS and there is no article in DTAA for taxing the FTS separately. Therefore, the payment made to the non resident required to be taxed under article 7 under the head ‘business profits’. - There is no PE in India to non resident. - Therefore, the payment made to non resident are not to be taxed in India as business profits - AT....