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Indo-German DTAA – As per new Treaty, income from supervision activity like construction & installation of a project is to be treated as income of PE provided that said activity continues for a period exceeding six months as per article 5(2)(i) of DTAA
Case Law Details
- Case Name
- ADIT(IT) Vs. Krupp UHDE GMBH (ITAT Mumbai)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Courts
- All ITAT, ITAT Mumbai
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DECIDED BY: ITAT, Bench `L’, Mumbai, IN THE CASE OF: ADIT(IT) Vs. Krupp UHDE GMBH, APPEAL NO: ITA No. 4496 & 4652/Mum/2005, DECIDED ON January 28, 2010
Order
Per: R S Padvekar:
These Cross Appeals, one by the Revenue and another by the assessee are directed against the order of the Ld CIT(A), Mumbai dt. 21.3.2005 for the A.Y. 2001-02.
2. We first take up the Revenue’s appeal for disposal in which the Revenue has taken the following Ground :
“1. On the facts and in the circumstances of the case and in law, the Ld. CIT(A) erred in holding that the amount of Rs.71,11,594/-...
