Gvk Inds. Ltd & Anr vs The Income Tax Officer & Anr

The Supreme Court ruled that the success fee payable to a non-resident company for financial advisory services rendered outside India does not attract tax liability under the Income-tax Act, 1961, specifically Sections 9(1)(i) and 9(1)(vii). The Court held that since the non-resident company had no business connection in India and the services were not rendered within the country, the income could not be deemed to arise in India. Consequently, the order of the Income Tax Commissioner revoking the permission to remit the fee was set aside, allowing the appellant to remit the payment without tax deduction.