India-Thailand Treaty: No Tax on Fees for Technical Services Without Permanent Establishment, Classified as Business Income.

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....Income accrued in India - Article for taxability of FTS under the India Thailand Treaty - Existence of PE in India - The assessee company has no Permanent Establishment (PE) in India. The income which has been earned in this case in absence of F.T.S. clause in DTAA would fall as business income. Their nature would not change to be that of other income. Hence the same cannot be taxed in India in absence of a PE. - AT....