#permanent establishment
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215 articlesIncome Tax
Income Tax
Maintenance of stock by customer does not constitute a PE of the foreign enterprise in India
Income Tax
Income Tax
To constitute fixed place permanent establishment three criterias needs to be satisfied
Income Tax
Income Tax
No permanent establishment under DTAA if three criteria are not fulfilled
Income Tax
Income Tax
Taxability of Payment for assignment of contractual rights in connection with the supply of products to foreign company not having PE
Income Tax
Income Tax
MNC preferring dispute resolution panel to settle their disputes with Income tax department
Income Tax
Income Tax
To compute the PE ‘duration test’ under Art. 5 (2) of the DTAA, different project sites can be aggregated only if the test of interconnection and interrelationship is satisfied
Income Tax
Income Tax
Fees received on assignment of contractual rights not taxable: Authority of Advance Ruling
Income Tax
Income Tax
Budget 2010: Direct and Indirect Tax Proposals for Oil and gas Sector
Income Tax
Income Tax
Taxability of payments received by applicant from its Indian re-seller for supply of software products to end users
Income Tax
Income Tax
Foreign company having Permanent Establishment in India cannot be taxed at the rate applicable to domestic company
Income Tax
Income Tax
If income attributable to PE in India less than the remuneration paid to the distributor in India by the taxpayer then no further income taxable in India
Income Tax
Income Tax
Tribunals upheld the concept of ‘make available’ and held specified services not Fees for technical services
Income Tax
Income Tax
Salaries paid by foreign company to its expatriates working in Indian branch office held to be allowable
Income Tax
Income Tax
