#permanent establishment
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212 articlesIncome Tax
Income Tax
Delhi ITAT: MAP Rate Not Binding After PE Functions Change, Attribution Cut 15% to 12%
Income Tax
Income Tax
Delhi ITAT Finds No PE for UK Offshore Services; Remands FTS ‘Make Available’ Test
Income Tax
Income Tax
Secondment Payments to Overseas Entities Taxable; Section 195 TDS Applicable: Delhi HC
Income Tax
Income Tax
APA Refund Reduces Taxable Royalty, No PE in India: Bombay HC
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Income Tax
Excess Royalty Refunded Under APA Cannot Be Taxed as Only Retained Amount Is Taxable: Bombay HC
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Income Tax
No Fixed Place PE in India as Customer Premises Were Not at Foreign Company’s Disposal: ITAT Delhi
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Income Tax
Double Taxation Relief: Rules and Benefits in India
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Income Tax
ITAT Delhi Deletes Section 44BB Addition as Revenue Failed to Establish PE in India
Income Tax
Income Tax
Only Solar Days Count for Determining PE Under India-Saudi Arabia DTAA: ITAT Bangalore
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Income Tax
ITAT Mumbai Deletes Tax Addition Since UAE Consultancy Firm Had No PE in India
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Income Tax
Remote access to customer systems for maintenance not create a PE in India: ITAT Delhi
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Income Tax
Service PE Not Created as Only Unique Solar Days Count Under India-US DTAA
Income Tax
Income Tax
India’s Evolving PE and Business Connection Tests – Post-Digital Economy BEPS Changes
Income Tax
Income Tax
