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Income Tax - Highlights / Catch Notes

Home Highlights December 2014 Year 2014 This

Reimbursement of salary cost treated as fees for technical ...

Case Laws     Income Tax

December 22, 2014

Reimbursement of salary cost treated as fees for technical services – Royalty u/s 9(1)(vii) – Indo-US DTAA - If there is a PE, then Royalty or FIS cannot be taxed under Article 12, albeit only under Article 7 of the DTAA - AT

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