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Only Solar Days Count for Determining PE Under India-Saudi Arabia DTAA: ITAT Bangalore

Case Law Details

Case Name
Electrical material Center Co. Ltd. Vs DDIT (International Taxation) (ITAT Bangalore)
Date of Judgement/Order
Only available for paid members
Related Assessment Year
2010–11
Advertisement Electrical material Center Co. Ltd. Vs DDIT (International Taxation) (ITAT Bangalore) No Permanent Establishment Created as Engineers Stayed Less Than 182 Days in India; FTS Not Taxable in India Without Specific DTAA Clause; ITAT Rejects Man-Day Calculation for PE Determination Under Tax Treaty; Service Income Held Non-Taxable in India Due to Absence of PE Under DTAA; ITAT Distinguishes Virtual Service Cases While Deciding PE Issue; Taxability of Technical Service Fees Sent Back to AO Due to Lack of Work Details; Residual Article in India-Saudi Arabia DTAA Bars Taxation of FTS...
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Author Info

CA Sandeep Kanoi
Qualification: CA in Job / Business
Company: Taxguru Consultancy
Location: Mumbai, Maharashtra
Articles Published: 18,676

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