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Income Tax - Highlights / Catch Notes

Home Highlights September 2015 Year 2015 This

Indo-UK DTAA - neither under Article 5(2)(k) nor under Article ...


Assessee's Distribution Fee Not Taxable in India Under Indo-UK DTAA; No Permanent Establishment Per Articles 5(2)(k) & 5(4).

September 19, 2015

Case Laws     Income Tax     AT

Indo-UK DTAA - neither under Article 5(2)(k) nor under Article 5(4) read with 5(5), the assessee has a PE in India and, therefore, the distribution fee received by the assessee can not be held to be taxable in India. - AT

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