Income Under Centralized Services Agreement Not Taxable in India Due to Lack of Permanent Establishment.

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....Income taxable in India - Management Support Charges - the fee received by the assessee under the Centralized Services Agreement cannot be treated as FIS either under Article 12(4)(a) or 12(4)(b) of the India–US Tax Treaty. As a natural corollary, it can only be treated as business income of the assessee. Hence, in absence of a PE in India, it will not be taxable. - AT....