Income Taxable Under FTS Requires Direct Enablement or Skill Transfer, Advisory Services Not Sufficient Without PE Connection

International Management Group (UK) Limited Vs CIT (Delhi High Court) In the case of International Management Group (UK) Limited vs. CIT (Delhi High Court), the court deliberated on several crucial aspects concerning the taxability of income derived by IMG UK from its activities in India under the Double Taxation Avoidance Agreement (DTAA). The case revolved around the interpretation of provisions related to business income and the existence of a Permanent Establishment (PE) in India. The primary issue before the court was whether the income earned by IMG UK, arising from its consultancy and a...