ETHIOPIAN AIRLINES GROUP ,ETHIOPIA vs. ACIT, INT. TAXATION CIRCLE-1(2)(2), DELHI
ITA 2201/DEL/2024[2017-18]Status: DisposedITAT Delhi05 Jun 2025AY 2017-18
Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahman
Section 115ASection 133ASection 147Section 195Section 9(1)Section 9(1)(vii)
Income-tax Act, a non-resident is chargeable to tax on income that is sourced in India. The source rules are given in section 5(2) and section 9 of the Income-tax Act. Under section 5(2) of the Act, a foreign company or any other non-resident person ... such royalty income under the domestic tax law i.e. under the provisions of Income-tax Act. Under the scope of source rule under section 5(2) of the Income-tax Act, the taxable income of the non-resident constitutes income from all sources that accrues or arises or is received
