ITAT Mumbai Cuts Through the Rough: No Attribution Without PE

Gemological Research (Thailand) Co. Ltd. Vs ACIT (ITAT Mumbai) ITAT Mumbai Cuts Through the Rough: No Attribution Without PE Gemological Services Outside India Can’t Be Taxed in India, Rules ITAT Case Background The Assessee, a Thailand-based company, is part of the GIA Group, internationally reputed in gem & diamond grading. It rendered diamond grading services to its Indian AE (GIA India Lab Pvt. Ltd.) & to third parties in India. Returned income: Nil, claiming receipts were not taxable in India under India–Thailand DTAA, as: Not “royalty” u/s Article 12. Not “fees for t...