October 2019

Section 9(1)(i) read with section 28(va) of the Act, Article 5(2)(1) of the India-US DTAA Consideration received for granting the right to render BPO services to group entities qualified as business income u/s 28(va) of the Act Such income was not taxable in India under the Act as well as the DTAA in absence of any business activity and PE in India

Geeta Jani | Dhishat B. Mehta
Chartered Accountants

2. TS-458-ITAT-2019 (Pune) Cummins Inc. vs. DDIT ITA No.: 2506/Pune/2012 A.Y.: 2008-09 Date of order: 7th August, 2019

 

Section 9(1)(i) read with section 28(va) of the Act, Article 5(2)(1) of the India-US DTAA Consideration received for granting the righ

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