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Article 10 of India-UK DTAA not applicable if assessee not participating in management & control of UK based Co.

August 26, 2020[2020] 118 taxmann.com 314 (Mumbai - Trib.)
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INTERNATIONAL TAXATION : Where assessee, a resident company, entered into agreement with a UK based company to produce, complete and deliver a feature film on payment of certain agreed consideration, in view of fact that said agreement was entered into between assessee and non-resident company on Principal to Principal basis and, assessee did not participate in management, control and capital of said company, provisions of article 10 of India-UK DTAA would not apply and, thus, amount remitted to UK based company was not taxable in India

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