Held that CIT(A) had rightly held that the income earned by the assessee under such contracts was effectively connected to a permanent establishment in India and was liable to be taxed at 40 per cent. on net income basis according to the Reserve Bank of India guidelines. (AY. 2012-13)
Dy. CIT(IT) v. DHV B. V. (2022) 94 ITR 46 (SN) (Delhi)(Trib.)
S. 44DA : Non-residents-Royalties-Computation-Permanent Establishment-All contracts negotiated and signed in India by branch head-Activities under each contract in India for more than six months-Income earned from contracts connected to Permanent Establishment in India-Taxable at 40 Per Cent. on net income basis in accordance with RBI guidelines.