COURT: | Delhi High Court |
CORAM: | R. K. Gauba J, Ravindra Bhat J |
SECTION(S): | 194-J, 9(1)(vii), Article 12 |
GENRE: | International Tax |
CATCH WORDS: | consultancy services, Fees for technical services, independent personal services |
COUNSEL: | Kaanan Kapur |
DATE: | May 29, 2015 (Date of pronouncement) |
DATE: | June 1, 2015 (Date of publication) |
AY: | 2004-05 |
FILE: | Click here to view full post with file download link |
CITATION: | |
S. 9, Article 12: Meaning of expressions "consultancy services" and "independent personal services" in the context of a DTAA explained |
It is evident that “consultancy services” would mean something akin to advisory services provided by the non-resident, pursuant to deliberation between parties. Ordinarily, it would not involve instances where the non-resident is acting as a link between the resident and another party, facilitating the transaction between them, or where the non-resident is directly soliciting business for the resident and generating income out of such solicitation
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