In absence of PE in India No tax on money received by IBM Philippines in the course of their business

Advocate Akhilesh Kumar Sah

DCIT, International Taxation Vs IBM India Pvt. Ltd (ITAT Bangalore)

IBM India Pvt. Ltd  case: IBM Philippines received the monies in the course of their business and did not have PE in India and therefore the receipt in question could not be brought to tax

Case in brief:

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