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Oracle India P. Ltd. not permanent establishment of Oracle Systems Corporation
Case Law Details
- Case Name
- Oracle Systems Corporation Vs ADIT (ITAT Delhi)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2006-07
- Courts
- All ITAT, ITAT Delhi
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Oracle Systems Corporation Vs ADIT (ITAT Delhi)
ITAT Delhi held that Oracle India Private Limited is an independent legal entity and existence of Oracle India Private Limited cannot be considered as permanent establishment of Oracle Systems Corporation. Hence, there is not question of attribution of profit to Permanent Establishment.
Facts- the assessee entered into a Software Support Service Agreement dated 1st June, 2003 with its 100% subsidiary in India namely Oracle India Pvt. Ltd., wherein the assessee has received royalty by way of 56% of the revenue transfers received ...
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