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Foreign company deemed to have PE in India, If few places in India were at disposal of its employees
Case Law Details
- Case Name
- Renoir Consulting Ltd. Vs DCIT -International Taxation (ITAT Mumbai)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Courts
- All ITAT, ITAT Mumbai
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CIT (Appeals) has inferred of the hotel/s, where the assessee’s employees stayed, as also serving as their work place. The communications between them and the head office, which is again a part of their work, has again admittedly been carried out in India and, as stated, from a place in the vicinity of the place of the stay. Two, though to no effect, so that whether the communication has taken place from the hotel room through the medium of internet using laptops – a tangible asset/s, by the personnel, or similar facilities provided by the hotel or by a retail outlet providing such...




