Saturday International Tax Gyan!! #taxmadeeasy #taxinpic
In case of absence of FTS clause in DTAA, income earned by providing engineering services in India would fall under business income and would be taxed in accordance with article 7 of DTAA [Deputy Director of Income Tax. Vs. Michelin ROH Co. Ltd., [2022] 138 taxmann.com 497 (Delhi – Trib.)]