Case Law Details
Case Name : M/S Nortel Networks India International Inc. Vs DIT (High Court Delhi)
Related Assessment Year :
Courts :
All High Courts Delhi High Court
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Brief:
The first three questions framed in the aforesaid appeals relate to the dispute whether the Assessee has a PE in India and the fourth question relates to the issue of attribution of income to the Assessee‘s alleged PE in India.
Q1. Appellant had a (PE) within the meaning of Article 5 of the DTAA between India and USA?
Ans: No as it doen’t includes the use of facilities solely for the purpose of storage, displa
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