Income Classified as Business Income, not Taxable in India for Non-Resident Assessee: ITAT upholds CIT(A) Ruling [Read Order]
The tribunal determined that the receipts, totaling ₹8,98,36,327, did not qualify as FTS under the India-Singapore DTAA, due to the absence of a PE and the non-fulfillment of the "make available" clause
The Delhi Bench of Income Tax Appellate Tribunal ( ITAT ) upheld the Commissioner of Income Tax(Appeals)[CIT(A)] ruling that the income received by a non-resident entity should be classified as business income and not taxable in India. The Revenue appellant filed an appeal against the CIT(A) order dated March 27, 2023. In this case Transkor…
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