Income Tax, HC Delhi Judgement Dated 08/07/2025 – Arbitral award for Offshore Supplies is Business Income, not taxable under DTAA 

Case of CIT vs Fujitsu Limited,  HC Delhi Judgement Dated 8th July 2025. High Court has upheld the decision of ITAT, declaring that an arbitral award received by respondent, a Japan-based tax resident, for non- payment of offshore supplies constitutes business income and is therefore not taxable in India under Article 7 of the India-Japan Double Taxation Avoidance Agreement (DTAA). 

(Link: HC Delhi Judgement Dated 08/07/2025)

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