Income earned in Absence of FTS clause in DTAA would fall as Business Income and cannot Taxed in India in Absence of PE: ITAT [Read Order]

By Taxscan Team - On June 1, 2022 9:12 pm - 2 mins read
Income - DTAA - Business Income - PE - ITAT - taxscan

The Delhi Bench Income Tax Appellate Tribunal has held that income earned in absence of Fee for Technical Service (FTS) clause in Double tax avoidance agreement (DTAA) would fall as business income and cannot taxed in India in absence of Permanent Establishment (PE). The assessee, Michelin ROH Co. Ltd., is a company incorporated in Thailand…

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