Income Tax : The guide explains how residents can avoid double taxation through DTAA benefits, Foreign Tax Credit, and Section 91 relief, outli...
Income Tax : The article explains how India has broadened Permanent Establishment and Business Connection concepts after BEPS reforms. It highl...
Income Tax : xplains how the functions performed by an Indian subsidiary are tested under Article 5 to determine whether a foreign company form...
Income Tax : The analysis explains how activities of a liaison office can trigger PE exposure despite regulatory approval. Taxability depends o...
Income Tax : Highlights how the Court ruled that consistent operational control and strategic oversight in India can establish a Fixed Place PE...
Income Tax : The OECD Committee on Fiscal Affairs has proposed important and far-reaching changes to the Commentary on Article 5 (Permanent Est...
Income Tax : A host of companies from Mumbai, said to be 367 in number and mostly multinational in nature, have moved the recently set up dispu...
Income Tax : A Double Taxation Avoidance Agreement was signed between India and Tajikistan today, i.e. 20th November, 2008. The Agreement was s...
Income Tax : The Bombay High Court held that only the royalty retained after an APA adjustment is taxable, applying the doctrine of real income...
Income Tax : The Bombay High Court held that royalty refunded by a foreign company to its Indian subsidiary under an Advance Pricing Agreement ...
Income Tax : The Delhi ITAT ruled that no installation or supervisory PE existed in India as the activities did not exceed the 120-day threshol...
Income Tax : The Tribunal held that offshore supply receipts could not be taxed under Section 44BB where the Revenue failed to prove the existe...
Income Tax : Bangalore ITAT ruled that only solar days and not cumulative man-days should be considered while determining the existence of a Pe...
Income Tax : CBDT notifies Section 206C (1G) of Income Tax Act shall not apply to a person (being a buyer) who is a non-resident & who does not...
Income Tax : Public Consultation on the proposal for amendment of Rules for Profit attribution to Permanent (PE) Establishment invited by CBDT....
Delhi High Court held that reassessment under section 148 of the Income Tax Act cannot be sustained since there is no tangible material for forming a belief that petitioners had a dependent Permanent Establishment or Fixed Place PE in India
Delhi HC rules for GE Renewables, setting aside tax reassessment for AY 2013-17 due to lack of tangible India PE evidence, citing prior GE cases.
Karnataka HC upholds Flipkart’s stance on TDS under Section 195, ruling seconded employees’ salaries as reimbursements, not taxable income for Walmart Inc.
Bangalore ITAT overturns AO’s PE classification of QlikTech India, orders fresh review based on TPO order, addresses TDS and interest issues.
Delhi High Court examines Nokia Network OY’s Permanent Establishment (PE) status in India, addressing taxation on software revenue, interest income & vendor financing.
Delhi HC rules Samsung India not a ‘Permanent Establishment’ of Samsung Korea. No tax liability under India-Korea DTAA for seconded employees’ roles.
Delhi HC rules Krones’ Indian subsidiary is not a Dependent Agent PE, dismissing the tax authority’s appeal.
Understand Permanent Establishment in India, its types, and the legal framework. Learn about taxation laws, DTAA provisions, and key judicial interpretations.
Delhi High Court clarifies taxability of profits attributed to a Permanent Establishment (PE) under the India-UAE DTAA, even when global losses are incurred.
Explore India’s income tax provisions for the digital economy, focusing on the concept of Permanent Establishment and recent legal developments.
