#permanent establishment
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215 articlesIncome Tax
Income Tax
PE or Business Connection – Tax on Income of non-resident in India
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TDS not deductible on Payment to Facebook Ireland for Advertisement
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No Supervisory PE established merely from visit of employees of Foreign Company in India for certain technical services
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Interest on income tax refund received by non-resident companies is taxable irrespective of PE
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No income of assessee-company taxable in India in absence of PE in India
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Income of ‘Sabre Asia Pacific’ from computerized Air ticket reservation taxable in India
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Profit attribution not permissible in absence of PE in India
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No attribution of profit in absence of permanent establishment
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Fixed placed PE or agency placed PE in India is must to determine taxability
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No further income attributable to a PE in India, if PE been remunerated at ALP
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Concept of Service PE and Key Judgements
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Taxable unit is a Foreign Company and not its Branch or PE in India
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Onus on Revenue demonstrate that PE of A Foreign Enterprise Exists In India
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