No Surcharge and Education Cess on tax rates prescribed under DTAA

JCDecaux S.A. Vs ACIT (ITAT Delhi) Conclusion: Surcharge and Education Cess was not leviable on receipts in the nature of Royalties and reimbursements of other expenses, which was offered to tax by assesse on gross basis under the India – France DTAA. Held: Assessee- company was incorporated under the laws of France. It was a holding company of “JCDecaux” group. During the relevant period, assessee company was engaged in the field of ‘outdoor advertising’. Assessee was owner of all intellectual property rights developed and used by the JCDecaux group across the gl...