Corporate tax alert has been saved
Corporate tax alert
No PE in absence of control over premises, income taxable as FTS
The Delhi Bench of the Income-tax Appellate Tribunal, based on facts, has rendered its decision that the taxpayer did not have permanent establishment (PE) in India and hence, the provisions of section 44DA of the Income-tax Act, 1961 (ITA) were not applicable. Further, the income of the taxpayer from engineering and project management consultancy services were taxable as fees for technical services under section 115A of the ITA.
