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Liaison Office Not a PE, Offshore Revenues & Interest Not Taxable in India: ITAT Delhi
Case Law Details
- Case Name
- DCIT Vs Hyundai Heavy Industries Ltd (ITAT Delhi)
- 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 Delhi
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DCIT Vs Hyundai Heavy Industries Ltd (ITAT Delhi)
Liaison Office Not a PE, Offshore Revenues & Interest Not Taxable in India – Revenue’s Appeals Against Hyundai Dismissed Completely
These three Revenue appeals arise from reassessment orders passed after remand by ITAT & subsequent relief granted by CIT(A). The core issues relate to (i) Whether the Assessee’s Mumbai Liaison Office constitutes a Permanent Establishment (PE) in India; (ii) Taxability of offshore revenues / Fees for Technical Services (FTS); (iii) Taxability of interest from Associated Enterprises (A...
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