No TDS on UAE Consultancy Payments as India-UAE DTAA Lacks FTS Article: Kolkata ITAT

Chowringhee Residency Pvt Ltd Vs ITO (International Taxation) (ITAT Kolkata) In Chowringhee Residency Pvt. Ltd. Vs ITO (International Taxation), the Kolkata ITAT considered whether payments made by the assessee to a UAE-based company for technical consultancy services were liable to tax deduction at source (TDS) in India and whether the assessee could be treated as an assessee in default under Sections 201(1) and 201(1A) of the Income Tax Act. The assessee, engaged in real estate development, was developing the residential project “The 42” in Kolkata. For this project, it entered into a Te...