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 services (such as chartered accountancy and management studies). The applicant is one of the member entities of Ernst & Young Global (EYG). EYG has such member entities in various countries. All member entities (including EYPL) use the brand `Ernst & young’ (EY) and adopt the international practices ...