Held that receipts from engineering services would fall under business income in accordance with article 7 of DTAA and in absence of the assessee’s PE in India, said receipts could not be brought to tax in India. (AY. 2016-17)
DCIT v. Michelin ROH Co. Ltd. (2022) 195 ITD 541 (Delhi) (Trib.)
S. 9(1)(i) : Income deemed to accrue or arise in India-Business connection-Engineering services to its Indian subsidiary-Absence of PE-Receipt is not taxable-DTAA-India-Thailand. [Art. 7, 12, 22]