Overseas Cricket Association's Termination Compensation Not Taxable in India Under Article 5(5) of India-South Africa DTAA.

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....Income taxable In India - Taxability of compensation paid to the overseas Cricket Association for the termination of the agreement - Dependent Agent Permanent Establishment (DAPE) - As the assessee cannot be said to be DAPE of CSA in India under Article 5(5) of the India-South Africa DTAA. Thus, the payment of compensation to CSA under the Termination Agreement is also not taxable under the provisions of the India-South Africa DTAA. - AT....