Business profits of non-resident US Company not having any PE in India would not be taxable U/s. 44BB as per article 7 of DTAA

HIGH COURT OF UTTARAKHAND Commissioner of Income-tax Versus Enron Oil & Gas Expat Services Inc.   IT APPEAL NOS. 33, 40, 41, 49 128 & 129 OF 2007 NOVEMBER 26, 2012 ORDER Barin Ghosh, CJ. All these appeals raise similar questions of law and facts and, accordingly, are taken up together and are decided by this common judgment. 2. Contents of Section 44BB of the Income Tax Act, 1961 (hereinafter referred to as “the Act”) are the mandate of legislation. The same cannot be contradicted in any manner or in any form. In the instant case, an instrumentality of th...