India and UAE DTAA not contain any article concerning FTS

WTS Energy Dmcc Vs DCIT (Delhi High Court) Double Tax Avoidance Agreement obtaining between India and UAE does not contain any article concerning FTS. The petitioner, who is a non-resident and does not have a PE in India, claims that the subject income is “business income.”  It is because of these varying stands, that a dispute arose with regard to the rate at which withholding tax had to be pegged. Thus, for the foregoing reasons, the rate of withholding tax, for the moment, will be pegged at 4%. The respondents/revenue will issue a certificate under Section 197 of the Act as expeditious...