Existence of Fixed Place Permanent Establishment (“Fixed Place PE”) and Supervisory Permanent...

Existence of Fixed Place Permanent Establishment (“Fixed Place PE”) and Supervisory Permanent Establishment (“Supervisory PE”) - India-Japan DTAA - Merely providing access to the premises by FRL for the purpose of providing agreed services by the assessee would not amount to the place being at the disposal of the assessee. - Since the goods were manufactured outside India, sale of goods took place outside India and consideration was also received by the assessee outside India, title passed outsi..... .....

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