Case Law Details
Case Name : Daikin Industries Ltd. Vs ACIT (ITAT Delhi)
Appeal Number : ITA No. 1623/Del/2015
Date of Judgement/Order : 28/05/2018
Related Assessment Year : 2006-07
Courts :
All ITAT ITAT Delhi
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Daikin Industries Ltd. Vs ACIT (ITAT Delhi)
Introduction:
Generally, it is seen in the Tax Treaties and Model Tax Conventions that, the Article 5 Clause 7 provides for that an entity which is resident of contracting state who is controlled by another entity who is resident of other contracting state will not be considered as PE in other contracting state.
Relevant Extracts from India – USA Treaty…………
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