#permanent establishment
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215 articlesIncome Tax
Income Tax
Tax Implications on Stewardship Activities
Income Tax
Income Tax
Indian subsidiary operating in independent manner doesn’t constitute PE
Income Tax
Income Tax
Section 44BB has no application in absence of Permanent Establishment
Service Tax
Service Tax
Fees paid to foreign institutions having permanent establishment in India is not covered under RCM
Income Tax
Income Tax
Without remote link between activities of other projects with PE, Force of Attraction Rule not apply
Income Tax
Income Tax
Business profit not taxable in India in absence of any permanent establishment
Income Tax
Income Tax
FTS service not taxable in India in absence of PE as FTS clause doesn’t exist in India-UAE tax treaty
Income Tax
Income Tax
Huawei India is permanent establishment of Huawei China in India
Income Tax
Income Tax
Subsidiary Company held as having Permanent Establishment in India
Income Tax
Income Tax
No further profit attribution to dependent agent PE in India as transaction with Indian AE is at arm’s length
Income Tax
Income Tax
Amount not being royalty cannot be brought to tax in India in absence of PE
Income Tax
Income Tax
Satellite Transmission Services cannot be treated as royalty
Income Tax
Income Tax
When software itself is not taxable, the training & related activities cannot be held to be FTS
Income Tax
Income Tax
