Dismissing the appeal of the revenue the Court held that reimbursement of lease line charges received by the assessee , a U.K company from Indian company is not liable to be assessed as business income or royalty . ( AY. 2007 -08)
CIT(IT) v. WNS Global Services ( UK) Ltd ( 2020) 117 taxmann.com 143 ( Bom) (HC) Editorial: SLP of revenue is dismissed , CIT v. WNS Global Services ( UK) Ltd ( 2020) 272 Taxman 431 / 117 taxmann.com 144 (SC)
S. 9(1)(i) : Income deemed to accrue or arise in India – Business income – Royalty -Lease line charges -Reimbursement – Not liable to be assessed as business income or royalty- DTAA-India -UK . [ S.9(1)(vi), Art, 7 ,12 ]