#permanent establishment
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215 articlesIncome Tax
Income Tax
SC: Substance over Form-Hyatt Ruling Strengthens India’s PE Jurisprudence
Income Tax
Income Tax
Hyatt International’s India Operations Held Taxable: SC Clarifies Scope of PE
Income Tax
Income Tax
Set off of loss of PE against interest income from External Commercial Borrowing allowed
Income Tax
Income Tax
ITAT Delhi allows Business Loss set off against FTS in case of PE
Income Tax
Income Tax
Reassessment quashed in absence of tangible material proving PE in India
Income Tax
Income Tax
Lack of India PE Evidence: Delhi HC Quashes Income Tax Reassessment
Corporate Law
Corporate Law
Reimbursement of Salaries to Seconded Employees Does Not Constitute FTS
Income Tax
Income Tax
Fresh Adjudication Ordered on TPO Adjustment in Subsidiary Transaction
Income Tax
Income Tax
Mere operational links or subsidiary relationships do not confer PE status: Delhi HC
Income Tax
Income Tax
Samsung India Not Permanent Establishment of Samsung Korea: Delhi HC
Income Tax
Income Tax
Indian Subsidiary Compensated at ALP Not a Dependent Agent PE: Delhi HC
Income Tax
Income Tax
Permanent Establishment: Concept and Its Application in Indian Context
Income Tax
Income Tax
Source State’s Right to Attribute Income to a PE Based on Global Income/Loss
Income Tax
Income Tax
