Sum paid to foreign entity for advertisement in foreign journals wasn't taxable in absence of its PE in India
ITAT Delhi bench held that where assessee had
made remittances to foreign countries related to
rent for office accommodation, expenses incurred
toward exhibitions outside India and
advertisement in foreign journals towards display
of its products, since foreign parties did not have
their PE in India, said payments were not
chargeable to tax in India.
Income-tax Officer, Ward 1 (1) (2), International
Taxation, New Delhi v. Brahmos Aerospace (P.)
Ltd. [2016] 74 taxmann.com 191
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