Offshore distribution commission income is business income

DCIT Vs Credit Suisse (Singapore) Ltd. (ITAT Mumbai) The assessee conducts portfolio investments in Indian securities in its capacity as SEBI registered FII/FPI, conclusion of the learned CIT(A) that the offshore distribution commission income is in th nature of ‘business income’ of the assessee does not require any interference. Facts- The assessee is a company incorporated in Singapore under the Singapore Companies Act. The assessee is a tax resident of Singapore and accordingly, is entitled to the beneficial provisions of India Singapore DTAA’. The assessee is registered as FII with S...