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In absence of PE Non-Competent Fee received by UK Company from Indian Company not Taxable in India: AAR
Case Law Details
- Case Name
- Mr. Kanchun Kaushal Vs Ms. Kavita Pandey (Authority for Advance Rulings)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Courts
- AAR Delhi, Advance Rulings
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Mr. Kanchun Kaushal Vs Ms. Kavita Pandey (AAR Delhi)
Non-compete fees received by the Applicant from ADI BPO Services Private Ltd., an Indian Company, as a part of the consideration for transfer of the shares held in MPS Ltd. an Indian Company, though income from “Profits and gains of business or profession” as provided under Section 28(va) of the Act, shall not be chargeable to tax in India in the absence of any Permanent Establishment of the Applicant in India, by virtue of Article 7 of the Double Taxation Avoidance Agreement (‘DTAA’) between India and United Kingdom...
