Overseas Consultancy Income is not business income taxable u/s 44DA

DCIT Vs Aecom Asia Co. Ltd. (ITAT Delhi) ITAT Delhi held that the assessee has rightly offered the Overseas Consultancy Income as fees for technical services under the provisions of section 115A of the Act and the addition made under section 44DA of the Act is liable to be deleted. Facts- The Appellant is a tax resident of Hong Kong having its registered office at Hong Kong. The Appellant, along with a consortium of members was awarded two projects namely, Chennai Metro Rail Project (‘CMRL’) and Kolkata East West Metro Rail Project (‘KMRL’). The Appellant provided both ...