ITAT explains impact on taxability when treaty not contains FTS clause

DCIT Vs Michelin ROH Co. Ltd. (ITAT Delhi)

Brief facts of the case are that the assessee has a company incorporated in Thailand and offers a number of services, such as, business planning and coordination, engineering services, product research and development etc. to its Indian subsidiary. On offering these engineering services, the assessee obtained a revenue of Rs.9,01,61,150. The assessee did not offer the aforesaid amount for tax as the DTAA between India and Thailand did not have any article pertaining to taxation of I

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