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ITAT Mumbai Cuts Through the Rough: No Attribution Without PE

Case Law Details

Case Name : Gemological Research (Thailand) Co. Ltd. Vs ACIT (ITAT Mumbai)
Related Assessment Year : 2019-20
Courts : All ITAT ITAT Mumbai
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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...
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Name: CA Vijayakumar Shetty
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Company: Shetty & Co, Chartered Accountants, Mangalore
Location: Mangalore, Karnataka, India
Member Since: 17 Feb 2018 | Total Posts: 5443
CA Vijayakumar Shetty qualified in 1994 and in practice since then. Founding partner of Shetty & Co. He is a graduate from St Aloysius College, Mangalore . View Full Profile

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