Service relating to mining of natural resources not taxable in terms of India-Portugal DTAA

Aluminium Pechiney Vs DCIT (ITAT Delhi)

ITAT Delhi held that amount received towards service rendered by the assessee is in connection with installation/erection of plant and machinery involved in mining of natural resources fall within the exceptions provided under Article 12(5)(f) and 12(5)(g) of India – Portugal DTAA and hence not taxable.

Facts- The assessee is a non-resident corporate entity incorporated in France and a tax resident of that country. Assessee owns ce

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