Royalty or technical charges income of non-resident taxable in India on receipt basis under India-Switzerland DTAA

ABB Switzerland Ltd Vs DCIT (ITAT Bangalore) ITAT Bangalore held that in case of non-resident, income arising in India by way of royalties or technical charges could be taxed in India but that could be only on the receipt basis under India-Switzerland DTAA and not on accrual basis. Facts- The assessee is a company incorporated and operating in Switzerland. The case was selected for scrutiny with a reason ‘International Transaction(s) in respect of intangible property and Large International transaction(s) Statutory notices were served on the assessee. During the assessment proceedings, the A...