OrbitaxDecision that income received from transfer of personnel and database taxable as "business profits"
|Approved Changes|India
The Indian Income Tax Appellate Tribunal (ITAT) delivered a ruling dated 2 March 2006 (reported in January 2007) in the case of IBM India Ltd v. Commissioner of Income Tax (2007-TIOL-22-ITAT-BANG) on whether consideration received for transfer of skilled employees and customer databases were liable to income tax as normal business income.
(a) Facts. The Taxpayer (i…
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