Whether on the facts and in the circumstances of the case and in law, the Tribunal was justified in holding that reimbursement of lease line charges by WNS India does not qualify as "Royalty" under Article 12(3) (b) of the India UK DTAA (Income Tax Appeal No. 890/15) and India US DTAA (Income Tax Appeal No. 891/15)?
Section 9 of the Income-tax Act, 1961—Income— Tribunal was justified in holding that reimbursement of lease line charges by WNS India does not qualify as "Royalty" under Article 12(3) (b) of the India UK DTAA and India US DTAA - Tribunal was justified in holding that the amount received as reimbursement of lease line charges is not liable to be taxed as business profit under article 7 read with article 5 of India UK DTAA and India US DTAA in view of the Force of Attraction Rule - CIT V/s WNS NORTH AMERICA INC. - [2018] 2 ITCD Online 124 (BOM)
Whether on the facts and in the circumstances of the case and in law, the Tribunal was justified in holding that reimbursement of lease line charges by WNS India does not qualify as "Royalty" under Article 12(3) (b) of the India UK DTAA (Income Tax Appeal No. 890/15) and India US DTAA (Income Tax Appeal No. 891/15)?
Section 9 of the Income-tax Act, 1961—Income— Tribunal was justified in holding that reimbursement of lease line charges by WNS India does not qualify as "Royalty" under Article 12(3) (b) of the India UK DTAA and India US DTAA - Tribunal was justified in holding that the amount received as reimbursement of lease line charges is not liable to be taxed as business profit under article 7 read with article 5 of India UK DTAA and India US DTAA in view of the Force of Attraction Rule - CIT V/s WNS NORTH AMERICA INC. - [2018] 2 ITCD Online 124 (BOM)