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Only Solar Days Count for Determining PE Under India-Saudi Arabia DTAA: ITAT Bangalore
Case Law Details
- Case Name
- Electrical material Center Co. Ltd. Vs DDIT (International Taxation) (ITAT Bangalore)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2010–11
- Courts
- All ITAT, ITAT Bangalore
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Electrical material Center Co. Ltd. Vs DDIT (International Taxation) (ITAT Bangalore)
No Permanent Establishment Created as Engineers Stayed Less Than 182 Days in India; FTS Not Taxable in India Without Specific DTAA Clause; ITAT Rejects Man-Day Calculation for PE Determination Under Tax Treaty; Service Income Held Non-Taxable in India Due to Absence of PE Under DTAA; ITAT Distinguishes Virtual Service Cases While Deciding PE Issue; Taxability of Technical Service Fees Sent Back to AO Due to Lack of Work Details; Residual Article in India-Saudi Arabia DTAA Bars Taxation of FTS...






