Accrual of income in India - existence of PE - business profits attributable to the PE - Entire profits...

Accrual of income in India - existence of PE - business profits attributable to the PE - Entire profits from supply of equipments and software cannot be attributed to the PE. The departmental authorities have not demonstrated in any financial terms, what is the exact role of the PE in earning the receipts and to what extent. Only that part of the receipts, which can be linked to the activities of the branch office, can be brought to tax in India by attributing to the PE. - AT .....

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