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Income Tax - Highlights / Catch Notes

Home Highlights February 2021 Year 2021 This

Income accrued or deemed to accrue in India - As the design ...

Case Laws     Income Tax

February 24, 2021

Income accrued or deemed to accrue in India - As the design services were inextricably connected with setting up of the plant and were rendered through this PE, the profit of the PE is required to be taxed in India as per the provision of Article 7.1 of the India-France DTAA in respect of these services. As the basic engineering design service and offshore advisory services are found covered under Article 7.1 of the DTAA, it is not necessary to examine whether the same are also covered under Article 13 of the DTAA or not. - AAR

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