Fixed placed PE or agency placed PE in India is must to determine taxability

DCIT Vs Western Union Financial Services Inc. (ITAT Delhi) Conclusion: In present facts of the case, the Hon’ble Tribunal relied upon the previous Judgments passed in the assesse own case and have observed that agents of the assessee did not have the necessary authority to conclude the contracts of the assessee and, on that premise, it was held that there is no agency PE of  assessee in India and therefore Assessee was not taxable in India. Facts: The brief facts of the case are that the assessee is a non-resident company registered in USA. It is engaged in the business of rendering money...