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Income to be taxable as business profit in lack of provision in DTAA between India-Philippines to tax FTS separately

April 29, 2020[2020] 116 taxmann.com 347 (Visakhapatnam - Trib.)/[2020] 182 ITD 45 (Visakhapatnam - Trib.)
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INTERNATIONAL TAXATION : There being no provision in DTAA between India and Philippines to tax Fees for Technical Services, payment made by assessee to avail technical service from its AE, would be taxed as per article 7 but, in absence to PE in India, same could not be taxed in India as business profits

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