Royalties & FTS are liable to tax as per Article 12 of the India-USA treaty only on payment basis

IN THE ITAT MUMBAI BENCH ‘L’ Booz. Allen & Hamilton (India) Ltd. Versus Assistant Director of Income-tax, (International Taxation) IT APPEAL NO. 4505 (MUM.) OF 2003 [ASSESSMENT YEAR 1998-99] DECEMBER 21, 2012 ORDER P.M. Jagtap, Accountant Member  This appeal is filed by M/s Booz. Allen & Hamilton (India) Ltd. & Co. Kg. (BAH India in short) as agent of Booz Allen & Hamilton, USA against the order passed by the learned CIT(Appeals)-XXXI, Mumbai dated 28th February, 2003. 2. BAH India is a foreign partnership firm established in Germany. It has a bra...