Case Law Details
Case Name : DDIT Vs. Western Union Financial Services Inc (ITAT Delhi)
Related Assessment Year : 2002- 03, 2003- 04 & 2005- 06
Courts :
All ITAT ITAT Delhi
Become a Premium member to Download.
If you are already a Premium member, Login here to access.
Sponsored
DDIT Vs. Western Union Financial Services Inc (ITAT Delhi)– ITAT held that the taxpayer’s agents in India were independent agents under Article 5(5) of the India-USA tax treaty (tax treaty). Accordingly, there was no Dependent Agent Permanent Establishment (DAPE) of the taxpayer in India. Further, the Tribunal observed that the taxpayer did not have right to enter and make use of the premises of the agents for its business. Accordingly, it was concluded that there was no fixed place PE of the taxpayer in India as per Article 5(1) of the
Please become a Premium member. If you are already a Premium member, login here to access the full content.
Sponsored
Kindly Refer to
Privacy Policy &
Complete Terms of Use and Disclaimer.