Allowing the appeal of the asseessee the Tribunal held that agent of assessee, a UK based company in India, had been paid arm’s length remuneration, and income embedded in such remuneration had been taxed in India, no further profits could be taxed in hands of DAPE. (AY. 2005-06)
OT Africa Line Ltd. v. DIT(IT) (2020) 183 ITD 159/192 DTR 241 / 206 TTJ 716 (Mum.)(Trib.)
S. 9(1)(i) : Income deemed to accrue or arise in India-Business connection-Dependent Agent-Arm’s length remuneration-DTAA-India-UK. [Art. 7]