SanDisk India is not DAPE of SanDisk Ireland: ITAT Bangalore

Western Digital Technologies Inc Vs DCIT (ITAT Bangalore) ITAT Bangalore held that SanDisk India [Western Digital India] is not a Dependent Agency Permanent Establishment [DAPE] of SanDisk Ireland and hence the assessee income is not chargeable to tax in India. Facts- The present appeal is preferred by the assessee against Final Assessment Order. The appellant has mainly contesting that AO/ DRP erred in treating M/s SanDisk India as a Dependent Agency Permanent Establishment (PE) of the assessee and, consequently, the taxation of the assessee’s income in India. Conclusion- Held that the ...