#permanent establishment
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215 articlesIncome Tax
Income Tax
LO doing preparatory activities in India not constitute PE under Article 5 of India Switzerland DTAA
Income Tax
Income Tax
In absence of PE Royalty Income of Warner Bros., USA arising outside India cannot be taxed
Income Tax
Income Tax
Fees for training to Employees on soft skill & general topics cannot be treated as FTS
Income Tax
Income Tax
PE commence with performance of business activities in connection with building site or assembly project
Income Tax
Income Tax
Analysis of Concept of ‘Place of Effective Management’ In India
Income Tax
Income Tax
DTAAs with special reference to DTAA between India and Singapore
Income Tax
Income Tax
BEPS – Latest OECD Transfer Pricing Guidelines – 2022
Income Tax
Income Tax
Exclusive Motors cannot be construed as a dependent agent PE of CCPL
Income Tax
Income Tax
HC upheld ITAT order attributing 15% of revenue to PE in India of Travelport L.P. USA
Income Tax
Income Tax
In absence of FTS clause Income is chargeable as Business profit & not taxable in absence of PE
Income Tax
Income Tax
Non residents having no PE in India exempted from section 206C(1G) TCS
Income Tax
Income Tax
Article 7 cannot come into play unless interest income is directly or indirectly attributable to PE
Income Tax
Income Tax
ITAT explains impact on taxability when treaty not contains FTS clause
Income Tax
Income Tax
