The Kolkata bench of the UTAT has held that the performance guarantee commission received from a Singapore entity cannot be taxable as royalty under the provisions of the DTAA between India and Singapore. The assessee, Dynamic Drilling, has challenged the disallowance of Rs.26,95,950/- in assessment year 2014-15 and Rs.28,10,930/- in assessment year 2015-16 on account…
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