S. 9(1)(vii):Income deemed to accrue or arise in India – Fees for technical services – Company providing advisory and consultancy services infield of real estate -Not having permanent establishment in India — Receipts not taxable as business income- DTAA- India- United Kingdom [ Art. 7, 13 ]
AAR held that company providing advisory and consultancy services in filed of real estate has no permanent establishment in India hence receipts are not taxable as business income considering the article 7 and 13 of DTAA between India and United Kingdom.