Tag: Permanent establishment
Project office used as auxiliary office for liaison not a PE unless core business is carried on therefrom – SC ABCAUS Case Law Citation:ABCAUS 3339 (2020) (07) SC Important case law relied upon by the parties:Commissioner of Income Tax and Another v. Hyundai Heavy Industries Co. Ltd., (2007) …
CBDT invites comments on report on Profit Attribution to PE in India. The Committee had examined the existing scheme under Article 7 of DTAAs, and recommended changes in Rule 10 Government of IndiaMinistry of FinanceDepartment of RevenueCentral Board of Direct Taxes New Delhi, 18th April, 2019 PRESS RELEASE …
Templates of Rulings received from other jurisdictions under BEPS Action 5. Ruling exchanged and approach to deal with it. Instruction No. 6/2018 F. No: 500/141/2018-FT & TR-V Government of India Ministry of Finance Department of Revenue Central Board of Direct Taxes Foreign Tax & Tax Research- II FT …
Mere outsourcing business to Indian subsidiary do not constitute Permanent Establishment within the meaning of Double Taxation Avoidance Agreement – Supreme Court ABCAUS Case Law Citation: ABCAUS 2105 (2017) (10) SC The Hon’ble Supreme Court of India in a recent judgment has laid down that outsourcing of services by …
PE under Indo-US DTAA-Adobe India not PE of Adobe Systems USA as agent must have authority to conclude contracts on behalf of the enterprise-Delhi High Court Case Details: WP(C) 2384, 2385, 2390 of 2013 Adobe Systems Incorporated (Petitioner) vs. Assistant Director of Income Tax & Anr (Respondents) Date of …
