Payments to Polish Law Firm Not Taxable in India: No Permanent Establishment Under India-Poland DTAA.

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....Income taxable in India - payments made to the law firm in Poland - nature of Fee for technical services under section 9(1) (vii) of the Act as well as Article 13 of India Poland DTAA - Nothing has been brought on record by the revenue to establish that the non resident payee has any fixed place of business PE in India. In that view of the matter, the income ceases to be taxable in India. - AT....