Thursday 17 May 2012

Under Article 7 of the DTAA, foreign PE profits may be taxed in India

Telecommunications Consultants India Ltd vs. ACIT (ITAT Delhi)


The assessee, an Indian PSU company, earned Rs. 10.68 crores from foreign projects in Oman etc. The assessee claimed that it had a “permanent establishment” (PE) in those countries and that in accordance with the DTAA, only the source country was entitled to tax the profits and India was not authorized to tax the foreign PE profits. HELD by the Tribunal rejecting the plea:

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All about Form 10AB in the context of Charitable Trusts:

1. Introduction: Every trust/charitable society/ NGO that wishes to claim the tax exemption benefits has to file Form 10A to seek fresh re...