Income deemed to accrue or arise in India - attribution made to the alleged PE - Ariba India has...

Income deemed to accrue or arise in India - attribution made to the alleged PE - Ariba India has retained majority of the revenues earned from the clients (around 88% to 97% from AY 2004- 05 to AY 2011-12) and offered the same to tax in India in its income tax returns for each of these years, only a miniscule percentage of the revenues (around 3% to 12.50%) have been paid to Ariba Inc. This clearly shows that there has been no base erosion in terms of taxes to be paid in India by the relevant pa..... .....

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