Law:

Section:

Section 90 of the Income-tax Act, 1961, read with articles 5 and 7 of the Double Tax Avoidance Agreement (DTAA) between India and United Arab Emirates - Double Taxation Relief - Where agreement exists - Applicant, a foreign company, is engaged in business of promoting golf nationally as well as internationally by way of organizing golf tournaments in different countries - It organized two golf tournaments in India, first in Delhi at Delhi Golf Club (DGC) and second in Bangalore at Eagleton Golf Resort (EGR) - For organizing those tournaments, it had entered into formal/oral agreements with DGC and EGR and had paid them a fee in consideration of granting of rights to use their premises - In wake of organizing those tournaments, it has received income from Indian sponsors in form of sponsorship fee, management fee and income from sale of merchandise - Applicant has sought advance ruling on its tax liability in respect of such income - Whether on facts, it can be said that by organizing and conducting golf tournaments at Delhi and Bangalore for a week's duration without repetition thereof, applicant has carried on business through a fixed place in India and, thus, it has a permanent establishment in India - Held, no - Whether income earned by applicant in India is liable to be taxed in India - Held, no FACTS The applicant, a foreign company, is engaged in business of promoting golf nationally as well as internationally by way of organizing golf tournaments in different countries. Its role is that of an event organizer which earns income by way of organizing such events. It organized two golf tournaments in India, first in Delhi at Delhi Golf Club (DGC) and second in Bangalore at Eagleton Golf Resort (EGR). For organizing those tournaments, it had entered into formal/oral venue agreements with DGC and EGR and had paid them fee in consideration of granting of rights to use their premises to host events which were sponsored by an Indian com- pany. The applicant had organized those tournaments by hiring independent third party local contractors and suppliers, having local expertise and experience. In fact, it had entered into a formal agreement with one consultant…

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