IT/ILT : Revenues earned by foreign company through its dependent agents who were assisting said company in operating websites in India was in nature of business profits as per article 7 of Indo-Swiss DTAA but could not taxed as assessee had no PE in India

IT/ILT : Revenues earned by foreign company through its dependent agents who were assisting said company in operating websites in India was in nature of business profits as per article 7 of Indo-Swiss DTAA but could not taxed as

assessee had no PE in India

[2013] 40 taxmann.com 20 (Mumbai - Trib.)

IN THE ITAT MUMBAI BENCH 'L'

eBay International AG

v.

Deputy Director of Income-tax (IT), Range -3(2), Mumbai