Professional charges paid by assessee to a non-resident company located in Bangladesh could not be brought to tax in India as royalty . Followed order of earlier year. ( AY. 2005 -06 to 2006 -07)
DCIT v. KPMG Advisory Services (P.) Ltd. (2018) 168 ITD 34 (Mum) (Trib
S. 9(1)(vi) : Income deemed to accrue or arise in India – Royalty – Professional charges paid by assessee to a non-resident company located in Bangladesh could not be brought to tax in India as royalty – DTAA- India – Bangladesh [ Art 13(2) ]