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

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