Saturday International Tax Gyan!! #taxmadeeasy #taxinpic
In absence of separate article of FTS in DTAA, such income shall be considered as business income and in absence of PE in India non resident is not required to pay tax in India. [Paramina Earth Technologies Inc v. Deputy Commissioner of Income-tax (International Taxation), Visakhapatnam [2020] 116 taxmann.com 347 (Visakhapatnam – Trib.)]