Income of non-resident attributed to its PE in India taxable as business profits; balance income not to be taxed as fee for technical services – ITAT Mumbai

Nippon Keiji Kyokoi Vs ITO (ITAT Mumbai)– Notwithstanding a change in the position by the assessee, the Tribunal has held that the effective connection with the permanent establishment in India has to be determined based on a functional test in the case of  fees for technical services . Furthe

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