Case Law Details
Case Name : DDIT Vs. Daimler Chrysler AG (ITAT Mumbai)
Related Assessment Year :
Courts :
All ITAT ITAT Mumbai
Court : Mumbai bench of the Income-tax Appellate Tribunal
Citation : DDIT Vs. Daimler Chrysler AG [2010-TII-99-ITAT-Mum-INTL]
Brief :
Recently, the Mumbai bench of the Income-tax Appellate Tribunal (the Tribunal) in the case of DDIT v. Daimler Chrysler AG [2010-TII-99-ITAT-Mum-INTL] dealt with the issue of Permanent Establishment (PE) under the India-Germany tax treaty (the tax treaty).
The Tribunal held that mere existence of subsidiary does not by itself constitute the subsidiary company a PE of the parent company. The main condition for constitution of PE is carrying on of business in India...
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