Amounts receivable by a British company (EMEIA) from the applicant under the Area Services & Market Development Agreement not liable to be taxed under the I-T Act as fee for `included services’ or as business profits under Indo-UK Treaty

AUTHORITY FOR ADVANCE RULINGS (INCOME-TAX) NEW DELHI,

Ernst & Young (P.) Ltd., In re,

APPEAL NO: AAR No. 820 of 2009,

DECIDED ON March 19, 2010

ORDER

1. The applicant, Ernst & Young Private Ltd. (EYPL) is a company incorporated in India and is engaged in providing consultancy service

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