Case Law Details
Case Name : HITT Holland Institute of Traffic Technology B.V. Vs DDIT (ITAT Kolkata)
Related Assessment Year : 2010-11
Courts :
All ITAT ITAT Kolkata
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Article 7(1) of the DTAA between India and Netherlands provides for taxing profits of the enterprise in the other state only to the extent they are attributable to the PE in the other state, adopting “No Force of Attraction” principle. With the above broad principles in mind we will now consider the facts of the present case and the rival contentions
Extract of the ITAT Judgment
This is an appeal by the Assessee against the order of D.D.I.T.(IT)-1, Kolkata (also referred to as AO) passed u/s 143(3) of the Act r.w.
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