Income deemed to accrue or arise in India - income attributable ...

Income from Canadian firm's distance learning sales not taxable in India under Article 7; DAPE status dismissed.

June 1, 2021

Case Laws     Income Tax     AT

Income deemed to accrue or arise in India - income attributable to India - As we have held that the ATC’s are not the DAPE of the assessee, therefore, the addition i.e 40% of the revenue generated from sale of distance learning material, attributed to them in their status as that of DAPE of the assessee corporation, viz. IATA, Canada, and assessed as the business income of the assessee in India under Article 7 of the India-Canada tax treaty cannot be sustained and is therefore vacated. - AT

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