Tribunal Rules Centralized Service Payments as Business Income, Not Taxable in India Due to No Permanent Establishment Under DTAA Article 7.

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....Income accrued in India - Centralized services fee received - royalty or fee for technical services The payments received were rightly held by the Tribunal, to be in the nature of business income. And since the assessee admittedly does not have a permanent establishment under the article 7 of the D TAA 'business income' received by the assessee cannot be brought to tax in India. - AT....