Without remote link between activities of other projects with PE, Force of Attraction Rule not apply
Case Law Details
Case Name : Lahmeyer International GmbH Vs DDIT (ITAT Delhi)
Related Assessment Year : 2008-09
Courts :
All ITAT ITAT Delhi
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Lahmeyer International GmbH Vs DDIT (ITAT Delhi)
ITAT Delhi held that the Force of Attraction Rule doesn’t apply unless there is even a remote link between the activities of other projects is established with the PE.
Facts- The assessee is a non-resident corporate entity incorporated under the laws of Germany and a tax resident of Germany.
In the assessment years under dispute, the assessee, as stated, had undertaken contract work with
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