Tax Dispute Resolved: UK Engineering Firm's Consulting Income Not Taxable Under India-UK Double Taxation Avoidance Agreement

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....ITAT resolved a tax dispute involving a UK-based engineering consultancy firm's income from services rendered in India. The Tribunal determined that payments received for consulting engineering services constitute business income under Article 7 of India-UK DTAA, not Fees for Technical Services (FTS). Since the company lacked a Permanent Establishment in India, the income was deemed non-taxable in India. The Tribunal upheld the assessee's position, consistent with its prior decisions in similar cases, and allowed the appeal, effectively exempting the income from Indian taxation.....