Income which cannot be taxed under article 7, 12 or 14 because conditions laid down therein are not satisfied cannot be taxed under article 23
Court :
INCOME TAX APPELLATE TRIBUNAL
Brief :
Whether on the facts and in the circumstances of the case, the learned CIT(A) was correct in holding that consultancy fees paid to Singapore based foreign company were not chargeable to tax in India, as well as the applicability of section 40(a)(ia) for failure of deduction under section 195
Citation :
Deputy Commissioner of Income Tax Circle 11, Kolkata ………………….Appellant Vs. Andaman Sea Food Pvt Ltd ………….……Respondent
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CS Bijoy
Published in Income Tax
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