S. 9(1)(vii):Income deemed to accrue or arise in India – Fees for technical services – Monies received towards arbitration costs and legal costs – Amount payable as per decree – Not liable to deduct tax at source -DTAA-India – Switzerland [S.190 , Art .22 Arbitration and Conciliation Act, 1996 S.48 ]
Xstrata Coal Marketing AG v. Dalmia Bharat (Cement) Ltd. (2019) 311 CTR 597/183 DTR 315 (Delhi)(HC)