Physical rendition of service in India required as virtual service PE not considered under India-Singapore DTAA: ITAT Delhi

Clifford Chance PTE Ltd Vs ACIT (ITAT Delhi) ITAT Delhi held that there is no provision regarding establishment of virtual service PE under India-Singapore DTAA and hence physical rendition of service in India is required under India-Singapore DTAA as per present service PE. Facts- The assessee is engaged in providing legal advisory services to several international clients including in India. It is a tax resident of Singapore and has opted to be governed by the provisions of India-Singapore Double Taxation Avoidance Agreement. The assessee’s cases were selected for scrutiny under CASS. Nota...