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If services rendered outside India by NR aren’t attributable to PE in India they are not taxable in India

August 26, 2016[2013] 32 54 (Bombay)/[2013] 214 Taxman 317 (Bombay)

IT/ILT : Fees received by assessee for providing marketing and management services outside India could not be subjected to tax in India, as same was not attributable to Permanent Establishment (PE) in India

IT/ILT : Reimbursement of lease line charges would not classify as royalty

IT/ILT : Entire income of assessee-non-resident being subjected to TDS it was not liable to pay interest under sections 234B and 234C
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