Delhi H.C : It is in the company of three other sections (which we have referred to earlier as 44BB series) specially providing for computation of profits of the non-residents/ foreign companies engaged in the specified types of business. True, profits arising from the business specified in section 44BB may also fall within the ambit of fees for technical services chargeable under section 9(1)(vii). But, the question is which is the appropriate computation provision that is applicable?
High Court Of Delhi Director Of Income Tax-II vs. OHM Limited Section 44BB, 44DA, 9(1)(vii) S. Ravindra Bhat & R. […]